United States Department of Agriculture

Travel Management on the Tonto National Forest Final Environmental Impact Statement Volume II–Response to Comments

Tonto Publ. No MB-R3-12-04 Forest Service National Forest June 2016

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In accordance with Federal civil rights law and U.S. Department of Agriculture (USDA) civil rights regulations and policies, the USDA, its Agencies, offices, and employees, and institutions participating in or administering USDA programs are prohibited from discriminating based on race, color, national origin, religion, sex, gender identity (including gender expression), sexual orientation, disability, age, marital status, family/parental status, income derived from a public assistance program, political beliefs, or reprisal or retaliation for prior civil rights activity, in any program or activity conducted or funded by USDA (not all bases apply to all programs). Remedies and complaint filing deadlines vary by program or incident. Persons with disabilities who require alternative means of communication for program information (e.g., Braille, large print, audiotape, American Sign Language, etc.) should contact the responsible Agency or USDA’s TARGET Center at (202) 720-2600 (voice and TTY) or contact USDA through the Federal Relay Service at (800) 877-8339. Additionally, program information may be made available in languages other than English. To file a program discrimination complaint, complete the USDA Program Discrimination Complaint Form, AD-3027, found online at http://www.ascr.usda.gov/complaint_filing_cust.html and at any USDA office or write a letter addressed to USDA and provide in the letter all of the information requested in the form. To request a copy of the complaint form, call (866) 632-9992. Submit your completed form or letter to USDA by: (1) mail: U.S. Department of Agriculture, Office of the Assistant Secretary for Civil Rights, 1400 Independence Avenue, SW, Washington, D.C. 20250-9410; (2) fax: (202) 690-7442; or (3) email: [email protected]. USDA is an equal opportunity provider, employer and lender.

Printed on recycled paper. Travel Management on the Tonto National Forest

Contents

Introduction ...... 1 Content Analysis of Public Comment on the Draft EIS ...... 2 Considering Different Types of Comments under NEPA ...... 2 Comments Specific to Routes ...... 2 Comments and Responses...... 4 Transportation Facilities ...... 4 Recreation Resources ...... 11 Wilderness, Wild and Scenic Rivers, Inventoried Roadless Areas, and Special Management . 44 Visual Resources/Scenery ...... 59 Socioeconomics ...... 61 Cultural Resources ...... 62 Game and Nongame Species ...... 63 Law Enforcement ...... 71 Soils and Water Resources ...... 87 Air Quality ...... 93 Climate Change ...... 102 Specific Routes ...... 104 Maps and GIS Data ...... 139 Implementation ...... 144 Invasive Species ...... 147 Power Company and Utilities ...... 148 Public Involvement ...... 157 General Analysis ...... 162 Purpose and Need ...... 170 Specific Alternatives...... 173 General Comments and Responses ...... 187

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Volume II–Response to Comments

Introduction This appendix includes a description of the formal public comment analysis and response to comment process and the comments received during the draft EIS comment period. Comments and our responses are organized by sections to mirror the order of the resource topics in the final EIS. This appendix also includes copies of the city, county, state, Federal, and Tribal agency letters received.

As a Federal agency, we are required by the National Environmental Policy Act (NEPA) to invite comments, After preparing a draft environmental impact statement and before preparing a final environmental impact statement the agency shall: (1) Obtain the comments of any Federal agency which has jurisdiction by law or special expertise with respect to any environmental impact involved or which is authorized to develop and enforce environmental standards. (2) Request the comments of: (i) Appropriate State and local agencies which are authorized to develop and enforce environmental standards; (ii) Indian tribes, when the effects may be on a reservation; and (iii) Any agency which has requested that it receive statements on actions of the kind proposed… (3) Request comments from the applicant, if any. (4) Request comments from the public, affirmatively soliciting comments from those persons or organizations who may be interested or affected. (40 CFR 1503.1(a))

On July 2, 2014, the notice of availability for the draft EIS was published in the Federal Register, marking the beginning of the 45-calendar-day comment period for this project. In response to several requests, Neil Bosworth, Supervisor of the Tonto National Forest, decided to extend the 45-day comment period by an additional 30 calendar days. On August 15, 2014, a notice to extend the comment period on the draft EIS was published in the Federal Register, extending the comment period to September 17, 2014. Approximately 2,500 comments were received during the comment period: 85 were original letters, while the rest were form letters generated by stakeholder groups.

NEPA also provides direction on the specificity of comments, indicating that, “comments on an environmental impact statement or on a proposed action shall be as specific as possible and may address either the adequacy of the statement or the merits of the alternatives discussed or both” (40 CFR 1503.3(a)). In addition, regulations specific to the Forest Service (36 CFR 218) require that to participate in a Project-level Predecisional Administrative Review Process, specific written comments must be submitted.

Written comments are those submitted to the responsible official or designee during a designated opportunity for public participation (§ 218.5(a)) provided for a proposed project. Written comments can include submission of transcriptions or other notes from oral statements or presentation. For the purposes of this rule, specific written comments should be within the scope

1 Travel Management on the Tonto National Forest

of the proposed action, have a direct relationship to the proposed action, and must include supporting reasons for the responsible official to consider. (§ 218.2) (emphasis added)

Finally, NEPA provides direction to Federal agencies related to responding to comments. Specifically,

An agency preparing a final environmental impact statement shall assess and consider comments both individually and collectively, and shall respond by one or more of the means listed below, stating its response in the final statement. Possible responses are to: (1) Modify alternatives including the proposed action. (2) Develop and evaluate alternatives not previously given serious consideration by the agency. (3) Supplement, improve, or modify its analyses. (4) Make factual corrections. (5) Explain why the comments do not warrant further agency response, citing the sources, authorities, or reasons which support the agency's position and, if appropriate, indicate those circumstances which would trigger agency reappraisal or further response.(40 CFR 1503.4(a))

Content Analysis of Public Comment on the Draft EIS Content analysis followed a systematic process of logging, numbering, reading, and coding all public comments that were submitted. The process ensures that every comment was read, analyzed, and considered.

Each response letter was read in its entirety and discrete comments identified within them. Each comment was assigned a unique tracking number and coded by document or resource topic, based on the action or change requested and the reason(s) behind it.

All original response letters, the coding structure, and other supporting documents are part of the project record. Considering Different Types of Comments under NEPA Agencies have a responsibility under NEPA to first “assess and consider comments both individually and collectively” and then to “respond…stating its response in the final statement.” The content analysis process described in the previous section considers comments received “individually and collectively” and considers them equally, not weighting them by the number received or by organizational affiliation or by any other status of the respondent.

All comments that were identified and coded as unique and pertaining to travel management on the Tonto National Forest were responded to, as detailed in the tables below. Comments Specific to Routes Comments that came in that identified specific routes were addressed at the district level, with input from district biologists, silviculturists, para-archeologists, and range and recreation staff,

2 Volume II–Response to Comments along with Forest Service law enforcement officers, Arizona Game and Fish Department Game enforcement officers, and district rangers, many of whom had participate in trips to the field to assess current conditions on the ground. These routes were reviewed based on use—either for public or permitted use access with an emphasis on assessing potential user conflicts—and resource protection—including effects to watersheds, vegetation, wildlife habitat, and water resources as required in the final Travel Management Rule (36 CFR 212.55). These meetings were conducted in late January and early February of 2015, and involved site-specific knowledge and the use of the most recent areal imagery.

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Comments and Responses Transportation Facilities Comment Letter Original Comment Text Forest Service Response Number Summarize the analysis contained in the Transportation Specialist Chapter 3 of the EIS is intended to be a summary of analysis reports in 2504 Report in greater detail in the FEIS. We recommend including a series order to ensure that the EIS is "kept concise and shall be no longer of maps displaying all existing and proposed motorized travel routes than absolutely necessary to comply with NEPA and with these for each project alternative. To the extent that site specific data are regulations (40 CFR 1502(c)). In addition, maps depicting all routes available for each affected resource area, that information should be within the Forest for each alternative were made available on the included or the corresponding pages of the Transportation Specialist project website at http://data.ecosystem-management.org/nepaweb/fs- Report should be cited. usda-pop.php?project=28967. Additionally, each resource analyzed the routes for each alternative and the effects associated with their designation. Discuss, in the FEIS, the effect of project implementation upon any According to comments published in response to the final Travel 2504 existing Forest maintenance backlog. To the extent that the Management rule (Federal Register, Volume 70, Number 216, page anticipated environmental outcomes are predicated on available 68269), the Forest Service appropriations are authorized by Congress. funding, the FEIS should describe the potential consequences should The Forest Service is committed to using whatever funds it has insufficient funds be available for required maintenance. available to accomplish the purposes of this final EIS in a targeted, efficient manner. The Agency makes appropriate use of all other sources of available funding, and has a number of successful cooperative relationships with State governments. Volunteer agreements with user groups and others have proven successful in extending Agency resources for trail construction, maintenance, monitoring, and mitigation. Regardless of the level of funding available, the Department believes that the final rule provides a better framework for management of motor vehicle use on national forests and national grasslands. While availability of resources for maintenance and administration must be considered in designating routes for motor vehicle use (§ 212.55), cooperative relationships and volunteer agreements may be included in this consideration. Furthermore, the EIS discloses the effects maintenance based on cycle-times in chapter 3, “Transportation Facilities” section. The federal legislation requiring the development of a motorized forest Comment is an opinion and lacks "supporting reasons for the 1716 road plan specifies that such road access should include a "network''. responsible official to consider" per 36 CFR 218.2. Nowhere in the

4 Volume II–Response to Comments

Comment Letter Original Comment Text Forest Service Response Number A network by definition consists of interconnecting trails, roads, etc. 2005 Final Travel Management Rule is there a requirement to develop The recommended proposal option fails to have connections to a "network" of motorized routes. However, when reviewing the road different motorized authorized trails. and trail system for this analysis, much of the consideration for the inclusion of routes was based the routes function and purpose, making sure that all routes connect to other routes and that there were no "hanging" routes that could not be accessed. In addition, the designated system includes opportunities for single track, less than 60 inches, and full-sized vehicle motorized trails. Any route that only has access from private property should be Thank you for bringing this to our attention. The needed edits the 5 eliminated from the maps and analysis, unless access to such a route database have been completed and these routes have been through the private property can be guaranteed. This applies to all designated as administrative use only, unless there is an existing alternatives. An example of such a route is W003 south of Strawberry easement that allows for public to travel through the private property. on alternative D. As we can get easements or other rights-of-way across private land, these routes may be open to public motorized use in the future. Greater clarity should be provided as to the actual expected The purpose of the EIS is to designate a system of roads and trails for 2471 maintenance schedule over the lifetime of the travel management motorized use as is required by the Travel Management Rule. plan. Implementation, including enforcement, of a travel management decision will be completed to the extent possible based on available resources. We plan to work in coordination with other Federal, State, and county agencies for enforcement and implementation of this decision. Include, in the FEIS, a description of road improvements needed to The purpose of the EIS is to designate a system of roads and trails for 2504 bring previously unclassified roads into the National Forest motorized use as is required by the final Travel Management Rule. Transportation System, such as resurfacing, ditching, culverts, and Implementation, including improvements to unauthorized routes vegetation removal. Descriptions should include the total length of adopted into the system, will be completed to the extent possible after each road and the number of stream crossings that are expected to the necessary compliance with NEPA for the site-specific nature of the need improvements. commenter's request. As this analysis is more akin to a programmatic analysis and will have little to no actually ground-disturbing activities associated with it. Details of needed improvements are not within the scope of the EIS. If improvements are required, further planning and public involvement will be done at that time. Though not directly addressed in the draft EIS, the amount of These routes are part of the analysis as they can still have effects to 5 "administrative use only" routes should be reduced to the absolute resources, such as hydrology and wildlife. Utilization of roads identified minimum. Such "administrative use only" should NOT be taken into as “administrative use only” is restricted to Forest Service personnel account in the EIS. That is, access routes open to the general public and emergency response personnel. Other authorized users of these should not be reduced as a result of impact generated by routes can include special use and grazing permittees; mining

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Comment Letter Original Comment Text Forest Service Response Number "administrative use only" routes. Doing so allows the private or companies; county, state, and Federal agencies; private landowners; privileged users of the national forest to penalize the general public and utility companies. The consideration for the amount of access. administrative use only routes being kept to a minimum fits within our process of designating these routes. In addition, the designation of administration use only was used to protect structures and improvements on the Forest, both Forest Service managed and permittee constructed. It makes sense to administratively close some roads. For example Utilization of roads identified as “administrative use only” is restricted 2405 roads that once extended through private land but where that access to Forest Service personnel and emergency response personnel. is now closed by the private land owner. Other examples where it may Other authorized users of these routes can include special use and be logical to administratively close roads would be to limit access to grazing permittees; mining companies; county, state, and Federal Forest Service administrative areas where security is a concern, high agencies; private landowners; and utility companies. The consideration value heritage sites that may be vulnerable, protection of riparian for the amount of administrative use only routes being kept to a areas, etc. However, it makes no sense to administratively close minimum fits within our process of designating these routes. In existing roads that have been providing, for years, access to the addition, the designation of administration use only was used to Forest backcountry and are needed as access, especially those roads protect structures and improvements on the Forest, both Forest where there will be no increase in resource damage as stated by the Service managed and permittee constructed. In addition, designating a interdisciplinary team specialists. route as administrative use only can help in the minimization of effects to resources, including heritage and cultural sites, while still allowing access for those permitted users. (See map below). Legend 8 Wlldlife Waters 0.3 0.6 1.2 Miles Roads in As indicted in the final EIS, chapter 2, alternative D was developed to 2405 red are administratively closed under Alternative C. Under Alternative address issues of providing motorized access to the current and future D they are designated as management level 2 (ML2) system roads. needs, specifically focusing on allowing as much public access as possible while still managing for the effects to natural resources. If wildlife, soils, or watershed resources are not the reason to change Utilization of roads identified as “administrative use only” is restricted 2405 the use of an existing road from open to one that is administratively to Forest Service personnel and emergency response personnel. closed, what were the factors? Even under the roads maintenance Other authorized users of these routes can include special use and discussion there was not any distinction made between grazing permittees; mining companies; county, state, and Federal administratively closed roads and other open roads when the cost agencies; private landowners; and utility companies. The consideration analyses was done (DEIS pg. 77). So we assume that if most for the amount of administrative use only routes being kept to a administratively closed roads were designated as motorized trails minimum fits within our process of designating these routes. In there would not be an increase in the cost of road maintenance. addition, the designation of administrative use only was used to protect structures and improvements on the Forest, both Forest Service managed and permittee constructed. In addition, designating a route as administrative use only can help in the minimization of effects to resources, including heritage and cultural sites, while still allowing

6 Volume II–Response to Comments

Comment Letter Original Comment Text Forest Service Response Number access for those permitted users. Costs for maintaining administrative use only can, through the use permit, be deferred to the National Forest System lands user. I wholly support the decommissioning of the unauthorized roads which An unauthorized route is not a National Forest System road or trail. It 2495 the FS has designated, provided that the roads are not cutting off is a route that is not "A road or trail wholly or partly within or adjacent access to viable camping areas for users of the Tonto. to and serving the National Forest System that the Forest Service determines is necessary for the protection, administration, and utilization of the National Forest System and the use and development of its resources" (36 CFR 212.1). We considered approximately 672 miles of unauthorized routes. Considerations to include a route or a portion of a route in our route system included access to designated camping areas. It should not designate any user created routes, especially those Comment is an opinion and lacks "supporting reasons for the 1101 created in the last decade. responsible official to consider" per 36 CFR 218.2. User-created roads and motorized trails may be identified through public involvement and considered in the designation process. After public consideration and appropriate site-specific environmental analysis, some user-created routes may be designated for motor vehicle use pursuant to 36 CFR 218 § 212.51 of the final rule. These routes would become National Forest System roads or National Forest System motorized trails and would be included in a forest transportation atlas and reflected on a motor vehicle use map. In addition, we designated nearly 100 miles of unauthorized existing routes as full-sized motorized trails specifically to access known dispersed camping sites. The TNF should not designate any user-created, unauthorized routes Comment is an opinion and lacks "supporting reasons for the 2471 through this action. responsible official to consider" per 36 CFR 218.2. User-created roads and motorized trails may be identified through public involvement and considered in the designation process. After public consideration and appropriate site-specific environmental analysis, some user-created routes may be designated for motor vehicle use pursuant to 36 CFR 218 § 212.51 of the final rule. These routes would become National Forest System roads or National Forest System motorized trails and would be included in a Forest transportation atlas and reflected on a motor vehicle use map. In addition, we designated nearly 100 miles of unauthorized existing routes as full-sized motorized trails specifically to access known dispersed camping sites.

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Comment Letter Original Comment Text Forest Service Response Number We again reiterate the requirements of the TMR and the Executive Nearly all unauthorized routes that have been designated for this 2471 Orders from which the TMR was derived to minimize the impacts of project have been review several times, including at the district level— the transportation system, not simply prevent significant harm. For any at the same time route specific comments were addressed—and unauthorized routes that are designated under this action, the Forest included input from district biologists, silviculturalists, para- Service MUST demonstrate how the minimization criteria of the TMR archeologists, and range and recreation staff, along with Forest were applied to specific routes. Service law enforcement officers, Arizona Game and Fish Department game enforcement officers, and district rangers, many of whom had participated in trips to the field to assess current conditions on the ground. These routes were reviewed based on use—either for public or permitted use access with an emphasis on assessing potential user conflicts—and resource protection, including effects to watersheds, vegetation, wildlife habitat, and water resources as required in the final Travel Management Rule (36 CFR 212.55). These meetings were conducted in late January and early February of 2015, and involved site-specific knowledge and the use of the most recent areal imagery. Instead of supporting the status quo, the Forest Service should only Comment is an opinion and lacks "supporting reasons for the 33 designate roads and trails that are needed to access designated responsible official to consider" per 36 CFR 218.2. No further response recreation sites and private lands. warranted. Only designate the roads and trails needed to access designated Comment is an opinion and lacks "supporting reasons for the 504 recreation sites and private lands. responsible official to consider" per 36 CFR 218.2. No further response warranted. The Forest Service should focus on designating a system of roads and Comment is an opinion and lacks "supporting reasons for the 1101 trails that are needed to access designated recreation sites and responsible official to consider" per 36 CFR 218.2. No further response private lands. warranted. It should not designate any user created routes, especially those Comment is an opinion and lacks "supporting reasons for the 1101 created in the last decade. responsible official to consider" per 36 CFR 218.2. User-created roads and motorized trails may be identified through public involvement and considered in the designation process. After public consideration and appropriate site specific environmental analysis, some user-created routes may be designated for motor vehicle use pursuant to 36 CFR 218 § 212.51 of the final rule. These routes would become National Forest System roads or National Forest System motorized trails and would be included in a Forest transportation atlas and reflected on a motor vehicle use map. In addition, we designated nearly 100 miles of

8 Volume II–Response to Comments

Comment Letter Original Comment Text Forest Service Response Number unauthorized existing routes as full-sized motorized trails specifically to access known dispersed camping sites. The only way that you can have credibility on road closures is to The purpose of the EIS is to designate a system of roads and trails for 2482 establish the standard that a road is open, unless it is marked closed. motorized use as is required by the Travel Management Rule. It is a good motivator for the FS to get out and mark the roads, Implementation, including enforcement, of a travel management because people will continue using the roads until they are marked decision will be completed to the extent possible based on available closed. If you go with the standard that a road is closed unless it is resources. We plan to work in coordination with other Federal, State, marked open, then people won’t know if the road is truly closed, or the and county agencies for enforcement and implementation of this FS just did not get around to mark it open yet. Plus it allows unethical decision. Furthermore, for designated motorized trails, the Forest has FS employees to create roadless areas just by not marking the roads developed a draft implementation plan that can be found on the project open. This is already occurring, in that the Tonto NF map that is sold website at http://data.ecosystem-management.org/nepaweb/fs-usda- to the public, does not show all of the trails that are currently legal to pop.php?project=28967. travel on, and there is no mention that the two northern ranger districts are open to cross-country travel. So for a person like myself, who as a matter of ethics, only travels on roads shown on the TNF map, roadless areas are created by FS employees who are concealing information. The fact that there are ranger districts open to cross country travel has been well hidden. I have been four wheeling in the TNF for over twenty years, and I have been around a lot of four wheelers, and I never was aware of that before. The TNF should provide an analysis of the fiscal consequences of According to comments published in response to the final Travel 2471 each alternative, including a description of how many routes are likely Management rule (Federal Register, Volume 70, Number 216, page to receive inadequate maintenance and management and the impacts 68269), the Forest Service appropriations are authorized by Congress. to the environment, public health, and access that might ensue. The Forest Service is committed to using whatever funds it has available to accomplish the purposes of this final EIS in a targeted, efficient manner. The Agency makes appropriate use of all other sources of available funding, and has a number of successful cooperative relationships with State governments. Volunteer agreements with user groups and others have proven successful in extending Agency resources for trail construction, maintenance, monitoring, and mitigation. Regardless of the level of funding available, the Department believes that the final rule provides a better framework for management of motor vehicle use on national forests and national grasslands. While availability of resources for maintenance and administration must be considered in designating routes for motor vehicle use (§ 212.55), cooperative relationships and volunteer

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Comment Letter Original Comment Text Forest Service Response Number agreements may be included in this consideration. Furthermore, the final EIS discloses the effects maintenance based on cycle-times in chapter 3, “Transportation Facilities” section.

10 Volume II–Response to Comments

Recreation Resources Comment Letter Original Comment Text Forest Service Response Number With the increase of motorized recreation, the amount of trails that can Under the “Public Comments on the Proposed Rule and Department 4 be accessed by these recreationalists needs to be recognized. The Responses” section of the 2005 Travel Management Rule (Federal more trails that can provide motorized recreation the better condition Register, Volume 70, Number 216 1192015, page 68283) states they will be in "Since the system of designated routes and areas will change over time, the Department anticipates that local units will publish new motor vehicle use maps annually and update signs as necessary or appropriate.” The designated roads, motorized trails, and areas will be reviewed annually. Whichever alternative is selected, routes that have historically been Under the “Implementation” subsection in the “Public Comments on 5 through/loop routes should remain as it was previously. This will result the Proposed Rule and Department Responses” section of the 2005 in less impact as travelers can complete the through route/loop instead Travel Management Rule (Federal Register Volume 70, Number 216 of being forced to return on the previously traveled route, therefore 1192015, pages 68269–68270), the Forest Service agreed that doubling the amount of impact. An example on Alternative C is route considerations such as designating loops may be important in local 894 which used to connect to route 1938. areas. On the Tonto National Forest, loops are built into the motorized transportation system both to increase public enjoyment of the system and to reduce impacts on the resources where ever possible. However, natural impacts such as fire or a flood may change an area such that a route is no longer safe as a loop opportunity. 894 and 1938 on maps, including aerials, appear to make a great looping alternative. However on the ground, 894 goes around the mountain and 1938 stops at a 1,500-foot overlook. It is important for us to "ground truth" many routes before designation. Trails are being ravaged by ATV. Certain trails must be closed near Comment is an opinion and lacks "supporting reasons for the 8 Payson. Boulders Loop, Cypress Trail, Monument Trail. Horrendous responsible official to consider" per 36 CFR 218.2. For the trails in damage. question, the decision is to convert or maintain all three of these trails for non-motorized use. I will say thank you for considering the publics' comments regarding Under the “Public Comments on the Proposed Rule and Department 13 motorized trails on the Tonto National Forest. As the population of the Responses” section of the 2005 Travel Management Rule (Federal region as well as the Phoenix Metro area grows and usership Register Volume 70, Number 216 1192015, page 68283) states "Since increases it is necessary to add, not take away, trails of all types for all the system of designated routes and areas will change over time, the users to make sure that people of all types and recreational Department anticipates that local units will publish new motor vehicle preferences can use their national forest responsibly. use maps annually and update signs as necessary or appropriate.” The designated roads, motorized trails, and areas will be reviewed annually.

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Comment Letter Original Comment Text Forest Service Response Number I believe that having designated routes for motorized use in adequate Comment is an opinion and lacks "supporting reasons for the 13 quantities and of adequate quality is the only way to ensure responsible official to consider" per 36 CFR 218.2. As a multiple use compliance with motorized use restrictions. agency, it is the intent of the Tonto National Forest to provide for all kinds of recreation opportunities while protecting natural resources. Many people want to have nature experiences, and not everybody Compliance with the final Travel Manage Rule is not expected to 13 wants to go out and do it on foot. I agree that there need to be resolve all Forest management issues. While management of restrictions on cross country travel, but overly reducing motorized motorized access on the Tonto National Forest will include increased access will decrease some peoples' connection with nature. management of motorized use across the Forest, it is not meant to make the Forest less accessible to the public. The travel management planning effort is meant to increase the effectiveness of managing motorized uses to reduce Forest impacts while still allowing multiple uses across the Forest. The designation of a system for motorized use has been implemented in other national forests throughout the Nation and has been studied showing an improvement in public lands management (Divine and Foti 2004). Has an environmental impact been performed to identify the possible The final EIS and final Recreation Resources report added an analysis 18 noise pollution that will be generated by this proposal?? Are there for user conflict. As part of that analysis, conflicts between motor noise restrictions that must be considered due to the proximity of vehicle users and adjacent landowners are addressed, including the residential area?? problem of noise associated with motor vehicles. This information can be found in chapter 3 of the final EIS. I agree with setting up designated places for riding because in all The draft record of decision identifies the designated motor vehicle 20 honesty I really don't know where I can or cant ride unless it is use system for the Tonto National Forest. The Travel Management physically posted. Rule was developed to assist the public with knowing where and when and what type of motor vehicle use was permitted on National Forest System lands. In accordance with CFR 36 212.56 "Designated roads, trails, and areas shall be identified on a motor vehicle use map. Motor vehicle use maps shall be made available to the public at the headquarters of corresponding administrative units and Ranger Districts of the National Forest System and, as soon as practicable, on the website of corresponding administrative units and Ranger Districts. The motor vehicle use maps shall specify the classes of vehicles and, if appropriate, the times of year for which use is designated.” The Forest Service has additional travel management guidance in its sign handbook to ensure consistent messages and use of standard interagency symbols for use during implementation.

12 Volume II–Response to Comments

Comment Letter Original Comment Text Forest Service Response Number I don't believe that the public (the owners of our Federal Land) can The purpose of the travel management planning is to determine where 22 truly appreciate and respect what incredible assets we have in public motorized vehicles routes can be sustainable and vehicles can be lands unless they are accessible. For many of us, motorized access is driven that minimize damaging resources. While this may not allow the the only practical method to reach these areas. Closing large parts of commenter to see the entire Forest, we have done our best to develop our public lands shuts out a large part of our citizenry from lands that a network of roads and trails that everyone can enjoy while minimizing have a stake in. I really wish we could develop a more effective way effects to the natural resources. to educate and enforce, rather than close access. Sensitive trails like the Boulders Loop and Monument Peat trails are Comment is an opinion and lacks "supporting reasons for the 27 being destroyed by ATV's. responsible official to consider" per 36 CFR 218.2. For the trails in question, the decision is to convert or maintain all three of these trails for non-motorized use. Meantime, sensitive areas are being damaged by motorized vehicles. Comment is an opinion and lacks "supporting reasons for the 32 responsible official to consider" per 36 CFR 218.2. No further response is warranted. Please design a final travel-management plan that respects quiet The final EIS and final Recreation Resources report added an analysis 33 recreationists, wild animals, and our precious forest resources by for user conflict. As part of that analysis, conflicts between motor limiting motorized vehicle use to those routes that are necessary for vehicle users and adjacent landowners are addressed, including the safe and efficient travel and have been designed to minimize problem of noise associated with motor vehicles. This information can environmental impacts. be found in chapter 3 of the final EIS. As a multiple-use agency, the Forest Service took all types of recreation, along with resource protection, into account when it developed the draft record of decision. I would like at this time to draw attention to a tremendously valuable Managing for quiet recreation is a policy that only the National Park 53 resource on quiet recreation and noise management, the National Service follows. The final EIS and final Recreation Resources report Park Service website on natural sound and quiet: added an analysis for user conflict. As part of that analysis, conflicts http://www.nature.nps.gov/sound/ The work done in the past decade between motor vehicle users and adjacent landowners are addressed, by the National Park Service (in the absence of adequate similar work including the problem of noise associated with motor vehicles. This either at the EPA or the USFS, or the BLM) is therefore invaluable as information can be found in chapter 3 of the final EIS. As a multiple- we move to deeper understanding and evaluation/assessment of use agency, the Forest Service took all types of recreation, along with soundscape as an important national resource. resource protection, into account when it developed the draft record of decision D. Just as with aircraft and helicopters, ORV's are another kind of Comment is an opinion and lacks "supporting reasons for the 53 recreational noise plague. Therefore, with growing public constituency responsible official to consider" per 36 CFR 218.2. The final EIS and on behalf of quiet recreation, it is incumbent on USFS to invest similar final Recreation Resources report added an analysis for user conflict. resources and management action against the ORV plague. As part of that analysis, conflicts between motor vehicle users and adjacent landowners are addressed, including the problem of noise

13 Travel Management on the Tonto National Forest

Comment Letter Original Comment Text Forest Service Response Number associated with motor vehicles. This information can be found in chapter 3 of the final EIS. As a multiple-use agency, the Forest Service took all types of recreation, along with resource protection, into account when it developed the draft record of decision. Designate defined areas for off-road users to be maintained by the Using the minimization criteria from the final Travel Management Rule 504 Forest Service using best-management practices with the goal of (36 CFR 212.55(b)), the designated OHV areas in the draft record of minimizing environmental impacts decision were analyzed to determine effects and to minimize them where possible. It would make much more sense to limit OHV (quad) access to a lot of Comment is an opinion and lacks "supporting reasons for the 554 areas since this type of transport has to be the most destructive of all responsible official to consider" per 36 CFR 218.2. As indicated in the motorized vehicles. Likewise quad operators tend to be at the upper draft record of decision, there will be four OHV areas where off-route end of the scale when it comes to irresponsible actions including travel is permitted, along with four areas specific to young riders, traveling cross-country. totaling approximately 2,000 acres. Maybe this is the time for the Tonto to make a bigger push for We appreciate your comment and the recognition of the importance of 554 volunteerism by the public. When I first applied to the Forest for this volunteering in the management of public lands. In the final EIS and activity, the nature of my proposed volunteerism was completely the draft implementation strategy, partnerships and volunteerism are unknown to the Service. Two years later I would like to think that my both identified as part of what will be required to ensure that the efforts have made the area much more amenable and visitor friendly. If implementation of the decision is successful. this type of volunteer work were expanded across the Forest, it would leave a positive impact for the land. I strongly protest any new road closures that limit handicapped In the Travel Management Rule (Federal Register, Volume 70, 842 persons the ability to hunt or explore OUR national forests. Number 216 1192015, page 68285) in response to a similar question concerning person(s) with a disability or senior citizens it states: “Under section 504 of the Rehabilitation Act of 1973, no person with a disability can be denied participation in a Federal program that is available to all other people solely because of his or her disability. In conformance with section 504, wheelchairs are welcome on all National Forest System lands that are open to foot travel and are specifically exempted from the definition of motor vehicle in § 212.1 of the final rule, even if they are battery powered. However, there is no legal requirement to allow people with disabilities to use OHVs or other motor vehicles on roads, trails, and areas closed to motor vehicle use because such an exemption could fundamentally alter the nature of the Forest Service’s travel management program (7 CFR 15e.103).

14 Volume II–Response to Comments

Comment Letter Original Comment Text Forest Service Response Number Reasonable restrictions on motor vehicle use, applied consistently to everyone, are not discriminatory." However, as someone who values wildlife, rivers and streams, and The final EIS and final Recreation Resources report added an analysis 1101 opportunity for quiet recreation, I ask that the Forest Service revise the for user conflict. As part of that analysis, conflicts between motor proposed management plan to better protect these resources. vehicle users and adjacent landowners are addressed, including the problem of noise associated with motor vehicles. This information can be found in chapter 3 of the final EIS. As a multiple-use agency, the Forest Service took all types of recreation, along with resource protection, into account when it developed the draft record of decision. I would like to comment on the subject of more Regulation of OHV use In the Travel Management Rule (Federal Register, Volume 70, 1436 in the National Forests. As a Arizona Native and former hunter, hiker Number 216 1192015, page 68285) in response to a similar question and Search and Rescue member (Pima County) I have been blessed concerning person(s) with a disability or senior citizens it states: with the ability to have traveled many a mile on foot, in Arizona's back “Under section 504 of the Rehabilitation Act of 1973, no person with a country. Today as a older person, with bad knees, severe Kidney disability can be denied participation in a Federal program that is Disease, and high blood pressure, there is no way I or my partner are available to all other people solely because of his or her disability. In able to get into the back country without an OHV. conformance with section 504, wheelchairs are welcome on all National Forest System lands that are open to foot travel and are specifically exempted from the definition of motor vehicle in § 212.1 of the final rule, even if they are battery powered. However, there is no legal requirement to allow people with disabilities to use OHVs or other motor vehicles on roads, trails, and areas closed to motor vehicle use because such an exemption could fundamentally alter the nature of the Forest Service’s travel management program (7 CFR 15e.103). Reasonable restrictions on motor vehicle use, applied consistently to everyone, are not discriminatory." We clearly need to close off road and trails due to the misuse of our Comment is an opinion and lacks "supporting reasons for the 1491 public lands by off-road vehicle use. responsible official to consider" per 36 CFR 218.2. The effects of soil erosion, water quality, and wildlife habitat are listed as the reasons for the Travel Management Rule. Motor vehicles are a legitimate and appropriate way for people to enjoy their national forests. However, the magnitude and intensity of motor vehicle use have increased to the point that the intent of E.O. 11644 and E.O. 11989 cannot be met while still allowing unrestricted cross-country travel (Federal Register, Volume 70, Number 216 1192015, page 68265–68266). With the designation of roads, trails, and areas the public will know where to recreate using a motor vehicle.

15 Travel Management on the Tonto National Forest

Comment Letter Original Comment Text Forest Service Response Number Do not be fearful of designating a single trail for motorized use that Comment is an opinion and lacks "supporting reasons for the 1716 passes through a larger area of nonmotorized use. responsible official to consider" per 36 CFR 218.2. The draft record of decision designates a system of motorized routes, including motorized trails. A complete list of these routes can be found in the project record. This will assist with developing a network of trails for motorized use. Using the minimization criteria from the final Travel Management Rule 1716 (36 CFR 212.55(b)), the designated motorized routes, including motorized trails in the draft record of decision were analyzed in the final EIS to determine effects and to minimize them where possible. A complete list of these designated routes can be found in the project record. The federal legislation requiring the development of a motorized forest Comment is an opinion and lacks "supporting reasons for the 1716 road plan specifies that such road access should include a "network''. responsible official to consider" per 36 CFR 218.2. Nowhere in the A network by definition consists of interconnecting trails, roads, etc. 2005 Final Travel Management Rule is there a requirement to develop The recommended proposal option fails to have connections to a "network" of motorized routes. However, when reviewing the road different motorized authorized trails. and trail system for this analysis, much of the consideration for the inclusion of routes was based the routes function and purpose, making sure that all routes connect to other routes and that there were no "hanging" routes that could not be accessed. In addition, the designated system includes opportunities for single track, less than 60 inches, and full-sized vehicle motorized trails. A complete list of these designated routes can be found in the project record. Dispersed camping should be authorized to at least 300 from roads. Motorized dispersed camping corridors of 300 feet from both sides of 1716 The purpose of dispersed camping is to disperse the campers. A all open roads was analyzed under alternative D in the final EIS. liberal dispersed camping policy reduces the crowding, reduces dust However, the draft record of decision designates “spur routes”, from passing vehicles, reduces noise, and improves the entire approximately 91 miles of motorized trails for full-sized vehicle use that camping experience. access 2,750 inventoried existing dispersed camping sites on the Tonto National Forest. As analyzed in the “Recreation” section of the final EIS, this will restrict motor vehicle use for dispersed camping and has the potential for competition for sites, concentration of use, and user conflict less than alternative D. Would love to see the camping at huston mesa left as is know the site None of the alternatives in the final EIS propose closing any existing 1720 is large and you might use part of it for other uses but horse men trails for non-motorized uses. This project will designated a system for would use it more if there were some other trails to ride on. Motorizing motor vehicle use to comply with the final Travel Management Rule. the open area will only cause ruin to the natural state of the forests. Therefore, non-motorized uses are outside the scope of this project.

16 Volume II–Response to Comments

Comment Letter Original Comment Text Forest Service Response Number Horse groups would use it more also if there was an easier way to get in to it as often the gate is shut and no won to open it for use. day or otherwise. Maintaining the trails that are designated as non-motorized (protect Comment is an opinion and lacks "supporting reasons for the 1983 the trails that are designated as non-motorized use and not let them responsible official to consider" per 36 CFR 218.2. Without more be reassigned as motorized use); specific information from the commenter, it is difficult to determine if they are indeed speaking about Forest Service designated non- motorized trails or user created trails that have been historically used by non-motorized recreationalists. Preventing motorized use on designated trails in close proximity to our The draft record of decision designates the second least amount of 1983 residential areas and communities; mileage of routes near the property of adjacent landowners of all action alternatives. More information about the effects to adjacent landowners from designating a motorized system of routes can be found in the “Recreation” section of the final EIS. Preventing motorized use on the Payson Area Trail System which Comment is an opinion and lacks "supporting reasons for the 1983 includes the Houston Loop Trail that was specifically designed for use responsible official to consider" per 36 CFR 218.2. All of the trails by the Houston Equestrian Horse camp, Monument Peak Trail, identified by the commenter will be designated for motor vehicle use. Boulders Trail (north and south, Cypress Trail, Peach Orchard Trail Specifically, Houston Loop Trail has been designated motorized to and Loop, Round Valley Trail, and American Gulch Trail. These allow access to the rest of the trails (Monument, Boulders, and specific trails are in close proximity to our homes and communities. If Cypress). Peach Orchard Trail provides for motorized trail opportunity motorized use is allowed it will affect the VALUES of our home, safety that connects to Main Street in the town of Payson. Round Valley Trail for our families, safety against fire, vandalism, noise pollution, air provides for motorized loop recreation, and American Gulch Trail pollution, protect our environment, erosion, water sheds, wells, wild life provides access to hunting, recreation, and natural resource survey habitat, beauty of our communities and the quality of life we all enjoy); opportunities. Town of Payson PATS stickers have been placed on Federal land trail markers that are designated for non-motorized use on the Illustrated Trail Maps #850 and #852 that is distributed and sold by the Payson Ranger District As a resident of Payson a frequent 2 track user in the Payson ranger Off-highway vehicle areas for each alternative are shown with acreage 2082 district, I sure hope there is a plan for a vast amount of acreage set in chapter 2 of the final EIS. No OHV areas are designated in Payson aside for OHV use. All the other districts have them. With the loss of in the draft record of decision. However, many motorized trails will be so many roads and 2 tracks its only fair that the Payson district be designated in Payson. Under the “Public Comments on the Proposed allowed to establish a designated area. Rule and Department Responses” section of the 2005 Travel Management Rule (Federal Register Volume 70, Number 216 1192015, page 68283) states "Since the system of designated routes and areas will change over time, the Department anticipates that local

17 Travel Management on the Tonto National Forest

Comment Letter Original Comment Text Forest Service Response Number units will publish new motor vehicle use maps annually and update signs as necessary or appropriate." The current designations are not intended to be last time we ever review the transportation plan. This will give all Forest users an opportunity to bring changes to our attention. Plan a blocked off area for ORV park and protect everything else. When developing the alternatives analyzed in the final EIS, we applied 2288 the minimization criteria identified in 36 CFR 212.55(b) to minimize damage to soil, watershed, vegetation, other forest resources, and disruption of wildlife habitats. The draft record of decision designates motorized travel off designated routes in four areas. Off-highway vehicle areas for each alternative are shown with acreage in chapter 2 of the final EIS. The draft record of decision also designates four permit zones, locations where motorized vehicles are restricted to designated routes and requires a permit for access. These are two examples of providing motorized opportunities while minimizing environmental impacts. The AES agrees with the response to one comment to the Final Rule, In the final Travel Management Rule (Federal Register, Volume 70, 2405 that Forests are managed by law for multiple use. We also agree that Number 216 1192015, page 68285) in response to a similar question users do not have a right to unrestricted use. However, motorized concerning person(s) with a disability or senior citizens it states “Under access to public lands is essential for the use and enjoyment of section 504 of the Rehabilitation Act of 1973, no person with a outdoor recreation, whether it is hunting or fishing, wildlife viewing, or disability can be denied participation in a Federal program that is just plain enjoying the outdoors. For the users who are aging, not in available to all other people solely because of his or her disability. In good health, or have disabilities, motorized access may be the only conformance with section 504, wheelchairs are welcome on all way one can access and enjoy the back country. National Forest System lands that are open to foot travel and are specifically exempted from the definition of motor vehicle in § 212.1 of the final rule, even if they are battery powered. However, there is no legal requirement to allow people with disabilities to use OHVs or other motor vehicles on roads, trails, and areas closed to motor vehicle use because such an exemption could fundamentally alter the nature of the Forest Service’s travel management program (7 CFR 15e.103). Reasonable restrictions on motor vehicle use, applied consistently to everyone, are not discriminatory." The net effect of motor vehicle use for dispersed camping for all action Motorized dispersed camping corridors of 300 feet from both sides of 2405 alternatives would be a negligible reduction in soil impacts when all open roads was analyzed under alternative D in the final EIS. compared to the No Action Alternative (DEIS pg.482). AES However, the draft record of decision designates “spur routes”, understands the need to limit where motorized dispersed camping can approximately 91 miles of motorized trails for full-sized vehicle use that

18 Volume II–Response to Comments

Comment Letter Original Comment Text Forest Service Response Number occur. However, we also understand that the quality of the user's access 2,750 inventoried existing dispersed camping sites on the experience is also important and no one wants to camp where they will Tonto National Forest. As analyzed in the “Recreation” section of the continually be covered with dust from the adjacent road. Because final EIS, this will restrict motor vehicle use for dispersed camping and there is negligible resource damage there is no reason why the Forest has the potential for competition for sites, concentration of use, and should not allow the least restrictive alternative which is 300 feet along user conflict less than alternative D. all routes where motorized use is allowed. The TNF should NOT include the Sycamore area as a permit zone for The Sycamore OHV Permit Zone is not designated in the draft record 2471 the purposes of this travel management decision. Rather, this area of decision in response to input questioning the ability to effectively should be designated as closed and be the focus of a rehabilitation implement controlled access for this area. However, any restoration effort. project would require separate environmental analysis in compliance with the National Environmental Policy Act. The TNF should provide more information about how the routes Permit Zones are areas where motorized vehicles have to stay on 2471 included within permit zones will be classified, maintained, and designated routes and cannot travel cross-country. They only differ enforced. from other designated routes in that they limit the number of ingress and egress points. Additionally, enforcement of the requirement to stay on designated routes may be easier as a permit is required for access, and the rules are provided with the permit. Route classification and maintenance are the same inside and outside of permit zones. As such, the routes inside permit zones are analyzed in the same manner as any other route in the final EIS. The TNF should incorporate the following management guidelines into Comment is an opinion and lacks "supporting reasons for the 2471 the planning for any designated permit zone and into the final travel responsible official to consider" per 36 CFR 218.2. Permit zones are management plan: o Establish regular patrols for these areas to only different in that they limit the number of ingress and egress ensure access infrastructure is maintained and in place and that points, and enforcement includes a permit requirement. Route unauthorized use is not occurring. o Provide posted signs at each site classification and maintenance are the same inside and outside permit showing the designated trail system (similar to those used for hiking zones. Measures needed for resource protection would also be the trail systems) and reminding riders that off-trail use is prohibited. o same inside and outside of permit zones. The Tonto National Forest Close areas when trail system is wet and soil resource specialists will also be working with volunteers to provide needed maintenance, concur that resource damage due to wet conditions would occur. o monitoring, and patrols in various areas of the Forest. We agree that Establish regular resource monitoring schedules for these areas to we need signs and/or physical barriers on the ground to enforce identify and prevent significant resource damage. o Establish an upper adequately. This is addressed as one of the minimum requirements in limit of users per day that may use the permit area. o Permanently or the “Law Enforcement” report in the final EIS. temporarily revoke access to users that are found to be in violation of the permit zone rules and regulations. o Prevent any access to riparian areas within permit zones.

19 Travel Management on the Tonto National Forest

Comment Letter Original Comment Text Forest Service Response Number The TNF should include the following statement as part of the record Under the “Public Comments on the Proposed Rule and Department 2471 of decision: Motorized designations in the Permit area will be Responses” section of the 2005 Travel Management Rule (Federal monitored annually after this Decision is implemented. If users Register, Volume 70, Number 216 1192015, page 68283) states continue to use non-designated routes and create new routes, destroy "Since the system of designated routes and areas will change over gates and signage, or violate road closures, then a closure to all over- time, the Department anticipates that local units will publish new motor the-ground motorized vehicle use in this area will be put into effect. vehicle use maps annually and update signs as necessary or This could also apply to other areas where enforcement is particularly appropriate." The designated roads, motorized trails, and areas in the problematic, where closures are implemented, or where sensitive selected alternative will be reviewed annually. More information can be resources exist. found in the final Law Enforcement report in the project record. The TNF should not designate OHV areas. Comment is an opinion and lacks "supporting reasons for the 2471 responsible official to consider" per 36 CFR 218.2. The draft record of decision designates four OHV areas, as analyzed in the final EIS. The final Travel Management Rule allows for OHV areas (Federal Register, Volume 70, Number 216, November 9, 2005, Rules and Regulations) "The agency must strike an appropriate balance in managing all types of recreational activities. To this end, a designated system of roads, trails, and areas for motor vehicle use, established with public involvement, will enhance public enjoyment of the National Forests while maintaining other important values and uses on National Forest System lands". The designation of tot lots where cross-country use is allowed should Comment is an opinion and lacks "supporting reasons for the 2471 also not be included in the final decision. If any tot lot is designated, it responsible official to consider" per 36 CFR 218.2. The final Travel should be as a permit zone with clear direction to stay on designated Management Rule allows for OHV areas (Federal Register, Volume routes. 70, Number 216, November 9, 2005, Rules and Regulations) "The agency must strike an appropriate balance in managing all types of recreational activities. To this end, a designated system of roads, trails, and areas for motor vehicle use, established with public involvement, will enhance public enjoyment of the National Forests while maintaining other important values and uses on National Forest System lands". In the draft record of decision, there are four proposed “tot lots” totaling approximately 12 acres. These areas would be limited to children and would allow them to learn to ride without the presence of other motorized users. For instance learning how to dress properly and start the vehicle, balance the vehicle if it is a motorcycle, etc. This requires an adult supervising the child by being right beside them.

20 Volume II–Response to Comments

Comment Letter Original Comment Text Forest Service Response Number This cannot be done on a designated route and is best done in an open area. The TNF should adopt the concept of motorized dispersed camping Per the final Travel Management Rule, "In designating routes, the 2471 site as outlined in Alternative B, but with the modification that parking responsible official may include in the designation the limited use of can only occur within one car-length from an open route. Any sites that motor vehicles within a specified distance of certain designated routes, are located in riparian areas, near archaeological resources, critical and if appropriate within specified time periods, solely for the purposes habitat, or other sensitive areas should not be designated under this of dispersed camping or retrieval of a downed big game animal by an action. Eliminating the corridor camping concept in favor of camping individual who has legally taken that animal" (36 CFR 212.51(b)). The sites will provide more than enough area for motorized dispersed draft record of decision designates “spur routes”, approximately 91 camping and will best alleviate significant and ongoing problems with miles of motorized trails for full-sized vehicle use that access 2,750 resource degradation and user conflict. inventoried existing dispersed camping sites on the Tonto National Forest. This concept is similar in nature to that suggested by the commenter. These spur routes already exist on the ground but will require additional analysis before they can appear on the motor vehicle use map. Further information can be found under alternative C in the final EIS. How deferred maintenance projects will be addressed in the future, Deferred maintenance is analyzed for all alternatives in the final 2471 and how lack of maintenance funding may impact any of the proposals Transportation Facilities report and summarized in chapter 3 of the included in the DEIS. final EIS. In addition, volunteers have enabled the Tonto National Forest to accomplish much needed trail maintenance, signing, fence construction, and visitor contacts with fewer dollars. Grants and other sources of funding would continue to be a viable option for increasing the Forest’s ability to maintain the motorized and non-motorized trail system. The TNF should identify priority areas for maintenance, or at least a The Tonto National Forest Land and Resource Management Plan, 2471 process to be used to identify such areas. The discussion should also October 1985, appendix F, explains road and trail maintenance levels. identify what type of work is included as maintenance. These levels are used to determine priority areas for maintenance based on public safety and protection of adjacent resources. Additional information can be found in the final Transportation Facilities report and summarized in chapter 3 of the final EIS. The TNF should disclose how shifts in funding for motorized trails will This information can be found in the final Transportation Facilities 2471 impact maintenance of non-motorized trails and the accompanying report and summarized in chapter 3 of the final EIS. Volunteers have user experience on those non-motorized trails. enabled the Tonto National Forest to accomplish much needed trail maintenance, signing, fence construction, and visitor contacts with fewer dollars. Grants and other sources of funding would continue to

21 Travel Management on the Tonto National Forest

Comment Letter Original Comment Text Forest Service Response Number be a viable option for increasing the Forest’s ability to maintain the motorized and non-motorized trail system. The TNF needs to identify and better analyze the problem of user Motor vehicles are a legitimate and appropriate way for people to 2471 conflict as it actually occurs on the forest. This is especially important enjoy their national forests. However, the magnitude and intensity of in the context of the executive orders mandate to minimize user motor vehicle use have increased to the point that the intent of E.O. conflict through travel management planning. The alternatives 11644 and E.O. 11989 cannot be met while still allowing unrestricted presented should provide options for better addressing user conflict, cross-country travel (Federal Register, Volume 70, Number 216 through the use of educational programs, volunteer activities, 1192015, page 68265–68266). With the designation of roads, trails, reduction in allowable motorized use, preservation of non-motorized and areas the public will know where to recreate using a motor opportunities, and better community engagement. vehicle. The final EIS and final Recreation Resources report added an analysis for user conflict. As part of that analysis, conflicts between motor vehicle users and non-motorized Forest users were addressed. This information can be found in chapter 3 of the final EIS. As a multiple-use agency, the Forest Service took all types of recreation, along with resource protection, into account when it developed the draft record of decision. The draft record of decision designates a system for motorized use while maintaining and improving Forest resources so that motorized and non-motorized Forest visitors can continue to experience and enjoy the Forest with less user conflicts. Restricting motorized use to designated routes and areas will reduce user conflicts by limiting interaction with users that are not required to stay on these motorized routes and areas such as hikers and other non-motorized visitors. Also by reducing the cross-country travel natural resources will begin to recover providing better habitat for wildlife and forest density. The designation of a system for motorized use has been implemented in other national forests throughout the Nation and has been studied showing an improvement in public lands management (Divine and Foti 2004). Increased help from volunteers, community involvement, and educational programs would no doubt be valuable in helping to manage Forest resources in addition to the Travel Management Plan and are being addressed in the draft implementation plan. My primary use of the TNF is exploring the NF in my highly modified, In the Travel Management Rule (Federal Register, Volume 70, 2482 high clearance OHV to find remote areas to explore on foot, and the Number 216 1192015, page 68285) in response to a similar question associated isolated dispersed camping that goes with the exploring. I concerning person(s) with a disability or senior citizens it states: am 66 year old retiree and I have had knee surgery. I can no longer “Under section 504 of person with a disability can be denied the

22 Volume II–Response to Comments

Comment Letter Original Comment Text Forest Service Response Number back pack great distances. If you close a road, I am excluded from Rehabilitation Act of 1973, no participation in a Federal program that is enjoying that part of the TNF. I know that you are not required to make available to all other people solely because of his or her disability. In all areas available to all people, but neither do you have a mandate to conformance with section 504, wheelchairs are welcome on all exclude as many people as possible National Forest System lands that are open to foot travel and are specifically exempted from the definition of motor vehicle in § 212.1 of the final rule, even if they are battery powered. However, there is no legal requirement to allow people with disabilities to use OHVs or other motor vehicles on roads, trails, and areas closed to motor vehicle use because such an exemption could fundamentally alter the nature of the Forest Service’s travel management program (7 CFR 15e.103). Reasonable restrictions on motor vehicle use, applied consistently to everyone, are not discriminatory." I do not want any trails closed, except for those that are in wilderness Comment is an opinion and lacks "supporting reasons for the 2482 areas. However, if a wilderness area has a road in it, it should not responsible official to consider" per 36 CFR 218.2. The draft record of have been designated a wilderness area in the first place. decision does not close any existing non-motorized trails since that is outside the scope of this project. The draft record of decision designates a system for motorized travel within the Tonto National Forest. There are no motorized trails or new roads proposed within wilderness area boundaries in compliance with the 1984 Wilderness Act. There are existing administrative roads within the wilderness area boundaries that will remain open for this use to access private property as allowed by other laws. The number of users to remote areas over Class 2 roads is going to be This final Travel Management Rule was developed in response to the 2482 reduced over time, as vehicles are no longer available that will substantial increase in use of OHVs on national forest lands and negotiate them. related damage to Forest resources caused by unmanaged OHV use over the past 20 to 30 years. The regulations implement Executive Order (EO) 11644 and EO 11989 regarding off-road use of motor vehicles on Federal lands. Four wheel drive, ATV, and side-by-side vehicle sales are increasing according to national sales information. There are many clubs in the state devoted just to four wheeling. There is also a steady business to make and repair four wheel drive in the valley. Although the number of people may change over time the users seem to keep growing. In reference to user conflicts: 25% of the TNF is wilderness area and Wilderness areas are indeed reserved for non-motorized use. In 2482 reserved for non-motorized users. If they want to be in an area that is addition the Forest uses the recreation opportunity spectrum to identify free of OHV use they can go to those areas. other areas for non-motorized recreation including primitive and semi-

23 Travel Management on the Tonto National Forest

Comment Letter Original Comment Text Forest Service Response Number primitive non-motorized areas. As noted in the Final Rule, page. 68266 (Federal Register, Volume 70, Number 216, November 9, 2005, Rules and Regulations) "National Forests should provide access for both motorized and non-motorized users in a manner that is environmentally sustainable over the long term. The National Forest System is not reserved for the exclusive use of any one group, nor must every use be accommodated on every acre. It is entirely appropriate for different areas of the National Forests to provide different opportunities for recreation." I believe the Sycamore Creek OHV area is important part of the travel Comment is an opinion and lacks "supporting reasons for the 2482 plan, in that it designates a place for the people who like to drive like responsible official to consider" per 36 CFR 218.2. Under the “Public maniacs a place to go, instead of them spreading out over the whole Comments on the Proposed Rule and Department Responses” section forest. I am not sure making the Rolls OHV area a permitted area is a of the 2005 Travel Management Rule (Federal Register, Volume 70, good idea. The responsible people, who get a permit will take better Number 216 1192015, page 68283) states "Since the system of care of it, but those irresponsible people who don’t, and find designated routes and areas will change over time, the Department themselves shut out, will just go somewhere else. Since you don’t anticipates that local units will publish new motor vehicle use maps have people to enforce the rules, illegal trails will be started in other annually and update signs as necessary or appropriate." The areas. designated roads, motorized trails, and areas will be reviewed annually. The first step of making users aware of the designated routes and areas will be the publication of the motor vehicle use map. As stated in the Law Enforcement specialist report, summarized in chapter 3 of the final EIS, the best chance of successfully enforcing any measure, regardless of the issue, is for the majority to understand the importance of the measure and thus want to comply. As it relates to the travel management planning, successful enforcement requires, at a minimum: (1) The majority of the public to understand the importance of the management plan, the rules of the management plan and have a desire to comply with those rules. The number of Forest Service law enforcement is small in comparison to the number of Forest visitors. Which means it is extremely difficult to educate the public in the field and achieve compliance. (2) State and local agencies must also understand the importance of the plan and be willing and active partners in implementing the plan. In order to address this, the Tonto National Forest has already developed a draft implementation strategy to address many, if not all of these issues (http://data.ecosystem-management.org/nepaweb/fs-usda- pop.php?project=28967).

24 Volume II–Response to Comments

Comment Letter Original Comment Text Forest Service Response Number Closing roads in the Tonto National Forest is discrimination against In the Travel Management Rule (Federal Register, Volume 70, 2482 physically handicapped and aged. Number 216 1192015, page 68285) in response to a similar question concerning person(s) with a disability or senior citizens it states: “Under section 504 of the Rehabilitation Act of 1973, no person with a disability can be denied participation in a Federal program that is available to all other people solely because of his or her disability. In conformance with section 504, wheelchairs are welcome on all National Forest System lands that are open to foot travel and are specifically exempted from the definition of motor vehicle in § 212.1 of the final rule, even if they are battery powered. However, there is no legal requirement to allow people with disabilities to use OHVs or other motor vehicles on roads, trails, and areas closed to motor vehicle use because such an exemption could fundamentally alter the nature of the Forest Service’s travel management program (7 CFR 15e.103). Reasonable restrictions on motor vehicle use, applied consistently to everyone, are not discriminatory." A trail needs to be added to complete the Highway To Hell Trail that Thank you for the support of the Travel Management planning 2482 starts on BLM land north of Trail 4 (Telegraph Canyon Trail) where it process. Constructing or building new trails on the Forest for public enters the BLM land. See Middle Gila Conservation Partnership access is outside of the scope of this project, but it does not preclude documentation for details. The Trail is NM2045B on the Middle Gila construction of trails in the future. The purpose of this project is to Canyons Area planning map. designate a system of routes and areas for motorized use on the Forest. On TMP Alt C, a portion of Trail 939 is shown as closed, from the As indicated in the draft record of decision, FR 939 from FR 134 to FR 2482 intersection of Trail 1936 to Gun Creek, this should be left open as it 1936 is designated a motorized trail. FR 393A which splits off south of accesses the Fred pantry Cabin and Gun Creek in the Tonto Basin 939 is decommissioned, as it does not contribute recreational Ranger District. opportunities or road network connectivity. Trail 38 should be left open to motorized vehicles, as it cuts off about Trail 38 is a non-motorized trail. The draft record of decision 2482 1,000 vertical feet and ½ the distance hiking the Pocket Trail out of designates only motorized routes and areas. The conversion of a coming out of Tonto Creek in the Hellsgate Wilderness. Trail 38 ends non-motorized trail to a motorized route, as the commenter requests at the wilderness boundary, where there is water and a unique place would require separate environmental analysis. to camp. The road is passable to a full sized pickup, if you don’t mind scratching the paint. At the wilderness boundary the road has been blasted off the side of a hill, and is impassable. If a person was traveling down Tonto Creek and wanted to exit the canyon via the Pocket Trail, during the summer, the extra distance and elevation gain could make a difficult hike a dangerous one.

25 Travel Management on the Tonto National Forest

Comment Letter Original Comment Text Forest Service Response Number There are two trails, without numbers that are shown as closed, off of It appears that you are referring to FR3413 and FR3411. As per 36 2482 Trail 894 in the Tonto Basin. There is no reason to close these trails as CFR 212.5(b) the "responsible official must identify the minimum road there is very little traffic on Trail 894, and the trails access the higher system needed for safe and efficient travel, utilization, and protection ground. of the forest system lands." These routes were not determined to contribute to road network connectivity or be of enough recreational value to be included in the proposed action. I am referring to the forest roads in the Pinal Mountains in Gila County In the Travel Management Rule (Federal Register, Volume 70, 2493 Az, and the wash/road leading from the Wheatfields area of Gila Number 216 1192015, page 68285) in response to a similar question County Az to the Salt River area named Horseshoe Bend. I am told concerning person(s) with a disability or senior citizens it states: this is now a WILDERNESS area, no motorized vehicles allowed. As I “Under section 504 of the Rehabilitation Act of 1973, no person with a am a disabled American who depends on my fully licensed, fully disability can be denied participation in a Federal program that is insured, fully road/highway accessable with a HOV tag permitting my available to all other people solely because of his or her disability. In access to any road in Az I object to this as a wilderness area denying conformance with section 504, wheelchairs are welcome on all me access to Horseshoe Bend. National Forest System lands that are open to foot travel and are specifically exempted from the definition of motor vehicle in § 212.1 of the final rule, even if they are battery powered. However, there is no legal requirement to allow people with disabilities to use OHVs or other motor vehicles on roads, trails, and areas closed to motor vehicle use because such an exemption could fundamentally alter the nature of the Forest Service’s travel management program (7 CFR 15e.103). Reasonable restrictions on motor vehicle use, applied consistently to everyone, are not discriminatory." I object to this, it is discrimination against the elderly and disabled. We In the Travel Management Rule (Federal Register, Volume 70, are being deprived of visiting this land. Number 216 1192015, page 68285) in response to a similar question concerning person(s) with a disability or senior citizens it states: “Under section 504 of the Rehabilitation Act of 1973, no person with a disability can be denied participation in a Federal program that is available to all other people solely because of his or her disability. In conformance with section 504, wheelchairs are welcome on all National Forest System lands that are open to foot travel and are specifically exempted from the definition of motor vehicle in § 212.1 of the final rule, even if they are battery powered. However, there is no legal requirement to allow people with disabilities to use OHVs or other motor vehicles on roads, trails, and areas closed to motor vehicle use because such an exemption could fundamentally alter the nature of the Forest Service’s travel management program (7 CFR 15e.103).

26 Volume II–Response to Comments

Comment Letter Original Comment Text Forest Service Response Number Reasonable restrictions on motor vehicle use, applied consistently to everyone, are not discriminatory." It is not Handicapp accessable, that is discrimination against the In the Travel Management Rule (Federal Register, Volume 70, elderly, and the handicapped. Number 216 1192015, page 68285) in response to a similar question concerning person(s) with a disability or senior citizens it states: “Under section 504 of the Rehabilitation Act of 1973, no person with a disability can be denied participation in a Federal program that is available to all other people solely because of his or her disability. In conformance with section 504, wheelchairs are welcome on all National Forest System lands that are open to foot travel and are specifically exempted from the definition of motor vehicle in § 212.1 of the final rule, even if they are battery powered. However, there is no legal requirement to allow people with disabilities to use OHVs or other motor vehicles on roads, trails, and areas closed to motor vehicle use because such an exemption could fundamentally alter the nature of the Forest Service’s travel management program (7 CFR 15e.103). Reasonable restrictions on motor vehicle use, applied consistently to everyone, are not discriminatory." In reviewing the DEIS, the FS has provided Alternatives B and C, Uncontrolled off-road vehicle use on the Tonto National Forest 2495 which in actually is controlling access to the forest in 5 areas through adjacent to the Phoenix Metropolitan Area has increased during recent decreased road mileage and creation of a permit system, instead of years and considerable environmental damage is occurring. These providing open access. I would question the use of this these two proposed management areas currently have heavily utilized, alternatives as the FS may be overstepping its authority and has not uncontrolled OHV use and it is damaging the soil and vegetation gone through the requisite administrative process to create a resources. This damage has a direct negative effect on wildlife permitting system. The creation of the additional "managed area" is habitat, visual quality, water quality, and other environmental tantamount to partial closures without justification. Therefore, components of these areas. Closing the area to vehicle use and Alternate's B and C are not appropriate for open access to the public. rehabilitating the damage would resolve the environmental concerns, however, it would prevent motorized access and enjoyment of these areas. Forest Service Manual 2350 states that one of our objective is to mitigate adverse impacts of recreational uses on natural, cultural, and historical resources and on other uses through education, outdoor ethics programs, and on-the-ground management, including law enforcement and restoration. Forest Service regulations do not prohibit on the ground management, such as requiring permits to access areas to minimize resource damage.

27 Travel Management on the Tonto National Forest

Comment Letter Original Comment Text Forest Service Response Number Allowing motorized vehicle access to persons obtaining written authorization (permits) would help manage these impacts of motorized recreational use on the resources through education and monitoring. These managed areas would be free of charge and all users can acquire access. The free permit system would be put into place as an alternative to creating a special recreation permit and charging a fee to access these high impact areas through the Federal Lands Recreation Enhancement Act Authority, or closing the areas completely to motorized use due to high adverse impacts to the resources. As discussed we are willing to assist in any possible manner the Tonto We acknowledge and appreciate the difference volunteers continue to 2500 needs as volunteers. make on the Forest. Volunteers have enabled the Tonto National Forest to accomplish much needed trail maintenance, signing, fence construction, and visitor contacts with fewer dollars. Maintaining the trails that are designated as non-motorized (protect Comment is an opinion and lacks "supporting reasons for the 2500 the trails that are designated as non-motorized use and not let them responsible official to consider" per 36 CFR 218.2. Without more be reassigned as motorized use); specific information from the commenter, it is difficult to determine if they are indeed speaking about Forest Service designated non- motorized trails or user created trails that have been historically used by non-motorized recreationalists. Preventing motorized use on designated trails in close proximity to our The draft record of decision designates the second least amount of 2500 residential areas and communities; mileage of routes near the property of adjacent landowners of all action alternatives. More information about the effects to adjacent landowners from designating a motorized system of routes can be found in the “Recreation” section of the final EIS. In regards to the Payson OHV Staging Areas and the Travel The draft record of decision does not designate staging areas. The 2500 Management Plan. 1. Consider areas of travel prior to staging areas. Payson OHV Staging and the Travel Management Plan is a separate 2. Staging areas should be close to areas with adequate travel for environmental analysis process. Under the “Implementation” section in motorized use. 3. Plan areas with numerous routes and or large loops. the “Public Comments on the Proposed Rule and Department 4. Plan travel to areas with destinations such as Tonto Natural Bridge, Responses” section of the 2005 Travel Management Rule (Federal stream fishing, water falls, rock climbing, and or wilderness areas that Register, Volume 70, Number 216 1192015, pages 68269–68270), the can be accessed by parking and walking in. 5. Adequate signage at Nf Forest Service agreed that considerations such as designating loops roads and trails marked with signage of uses to provide users for may be important in local areas. On the Tonto National Forest, loops safety and prevent "cross country travel". 6. Adequate placement of are built into the motorized transportation system both to increase signage within the trails system so riders will remain on specified trails. public enjoyment of the system and to reduce impacts on the 7. Eliminate dead ends to prevent cross country travel. 8. If allowing resources where ever possible. According to the final Travel dead-end trails for hunters to get to remote areas, consider placing Management Rule, "Designated roads, trails, and areas shall be

28 Volume II–Response to Comments

Comment Letter Original Comment Text Forest Service Response Number signs at beginning of trail so riders know it is a dead end. This will also identified on a motor vehicle use map" 36 CFR 212.56. Additionally, assist with less cross country travel. 9. Adequate and accurate "However, the final rule will enhance enforcement by substituting a mapping is necessary for "Travel Management". regulatory prohibition for closure orders and providing for a motor vehicle use map supplemented by signage" (Federal Register, Volume 70, Number 216, page 68270). A map (even one that is infinitely better than what we are proposing) is not an enforcement strategy that our enforcement officers believe will succeed on its own. We need an excellent map and we have plans to augment the required map with more detailed maps depicting popular areas. We anticipate providing digital mediums as well. We need signs and/or physical barriers on the ground to enforce adequately. This is addressed as one of the minimum requirements in the Law Enforcement report in the final EIS. Local residents have looked at staging areas and use-ability and have The draft record of decision does not designate staging areas. The 2500 found a few that would make excellent staging, riding and camping Payson OHV Staging and the Travel Management Plan is a separate area possibilities with very little cost. They are all within 10 miles of the environmental analysis process. We hope you will submit these Town of Payson. Photos included of staging areas. comments to any proposed projects considering staging areas. #1 Ranger Angela Elam suggested Nf 198 for a Camping The draft record of decision does not designate staging areas. The 2500 facility/Staging area. It would be perfect!!! With the Blue Ridge water Payson OHV Staging and the Travel Management Plan is a separate system running in close proximity and away from residents and a large environmental analysis process. We hope you will submit these loop which will access beautiful views and numerous areas of interest. comments to any proposed projects considering staging areas. Rock climbing which numerous individuals participate in at Pyeatt Draw. Views are beautiful and access is excellent. From high desert to tall pines. Great access!! "Staging Area" is on South side of State Highway 260, east of Star The draft record of decision does not designate staging areas. The 2500 Valley on road? (u1268-1270) Area is on Nf 436 Road (Preacher Payson OHV Staging and the Travel Management Plan is a separate Canyon Area/ brush pit area) a. Nf 656. Large parking area and environmental analysis process. We hope you will submit these numerous individual camping sites nestled in the trees to the west comments to any proposed projects considering staging areas. edge of parking area. This is a large parking area. Beautifully nestled within mountains and accessible to a huge amount of trails that could take a rider all the way down to Geisela with numerous loops and trails available. The entrance road is directly off of Highway 260. Arizona Public Service has a station farther up to the N.E. Prior to the APS station on the Nf 436 on the right is Nf 656 follow that down and it opens up to huge open area. The google earth map will show you the numerous trails and roads available from this area. The road is nice and wide for large vehicles and trailers even motor homes. There is an

29 Travel Management on the Tonto National Forest

Comment Letter Original Comment Text Forest Service Response Number area of road that would need some attention due to the vast amount of rain we have had in the past month. Still very use-able. Photos attached "Staging Area" is on South side of State Highway 260 east of Star The draft record of decision does not designate staging areas. The 2500 Valley on road? (u1268-1270) Area is on Nf 371 (Preacher Canyon Payson OHV Staging and the Travel Management Plan is a separate Area/ brush pit area) just before 371 curves to the right. Parking area environmental analysis process. We hope you will submit these is on the left side of Nf 371. Large parking area. This will access same comments to any proposed projects considering staging areas. areas as #1 due to close proximity. See Google Map for trails. Photos attached. "Staging Area" is on North side of State Highway 260 (Nf 365) This is The draft record of decision does not designate staging areas. The 2500 a very nice staging area (not as desirable for camping). Huge flat Payson OHV Staging and the Travel Management Plan is a separate parking area with a nice base of granite already down. This area environmental analysis process. We hope you will submit these connects to ?? unknown trail running east to west of highway 260 and comments to any proposed projects considering staging areas. connects to 1293a to 364a to 654 and then to 433 to 1602 to 1256 to Pyeatt Draw area and over to 198 and up to Control Road, or you can go south on 1258 to staging area on Nf 198 or you may go east on Nf 198 to Control Road and south on 65 for look out tower, Arizona diamond hunting area and then south on 1293 or 364 to 1293 and return to "Staging Area at 365. Staging area is high desert and turns into tall pines as you go farther north. More riding trails north of control road. Photos attached "Staging Area" is on North side of State Highway 260 at Nf 1368. This The draft record of decision does not designate staging areas. The 2500 would eliminate use of Mayfield Canyon as a staging area. Mayfield Payson OHV Staging and the Travel Management Plan is a separate Canyon has numerous archeological sites that should not be disturbed environmental analysis process. We hope you will submit these and is in close vicinity to non-motorized Houston Loop which is trail for comments to any proposed projects considering staging areas. the "Equestrian Horse Camp". Additional trails are needed from the horse camp and maps provided at the campgrounds for these trails. It is not appropriate for safety for horsemen and residents to have motorized trails in close vicinity of residents in Payson and Star Valley. Decommission Nf 654 from State Highway 260 north to Nf 1368. Use The draft record of decision does not designate staging areas. The 2500 Nf 1368 as a small staging area which will take riders north to 654 Payson OHV Staging and the Travel Management Plan is a separate connect to 433. Nf 433 as compromise multi use. Nf 433 will connect environmental analysis process. We hope you will submit these to Control Road, etc. Maintaining quiet recreation to the east side of comments to any proposed projects considering staging areas. Diamond Point Shadow residents.

30 Volume II–Response to Comments

Comment Letter Original Comment Text Forest Service Response Number Staging Area close to Rye Nf 442 and 414. Huge amount of trails. Can The draft record of decision does not designate staging areas. The 2500 ride all the way up to Tonto Natural Bridge and or take numerous small Payson OHV Staging and the Travel Management Plan is a separate loops. Place staging area close to Four Seasons Motorsport. Have environmental analysis process. We hope you will submit these them give educational classes on OHV, sell Tonto use permits and comments to any proposed projects considering staging areas. assist in maintaining trails in that area. This would benefit both parties economically. I believe they are open on week-ends and closed a few days during week. Eliminate Jim Jones Shooting Range Road Nf 208 as staging area. The draft record of decision does not designate staging areas. The 2500 Replace with #7. Too close to residents in Round Valley (inappropriate Payson OHV Staging and the Travel Management Plan is a separate for residential area). Safety issues with Jim Jones Gun Range. The environmental analysis process. We hope you will submit these gun range penetrates the residential area with noise from shooting. comments to any proposed projects considering staging areas. Many archeological sites in the area. Safety issues concerning shooters and riders. Range cattle permits in the area between Geisela and Round Valley. Round Valley is a horse community and so is Geisela. Most of the roads of travel are large jeep roads, horse community. Non-motorized improved trail system would be a nice addition on north side of Nf 208 to 375b. Nf 208 (Jim Jones Shooting Range Road) needs fencing placed on north side of road to prevent motorized use behind residential area to prevent any more erosion to the area. We personally drove the Main trail from behind Round Valley down to Gisela. Nf 208 in very good shape, blind corners. Destination is Geisela. Personally wouldn't waste time or money on staging area on Jim Jones better used on west side of State Highway 87. Add a staging area at Nf 583 and Nf 168 (turn off to Tonto Natural The draft record of decision does not designate staging areas. The 2500 Bridge) Could be an all day excursion for OHV riders, starting and or Payson OHV Staging and the Travel Management Plan is a separate ending by Tonto Natural Bridge or completing a "large loop" back to environmental analysis process. We hope you will submit these original start (Rye area). As a resident and OHV rider I myself would comments to any proposed projects considering staging areas. love to do that. I'm sure others would to. Roads and trails would need to be accurately marked. Increase revenue for Tonto, selling OHV permits, etc. Provide a great experience for multi-use-ability. No photos. SCI supports an alternative that provides adequate camping Non-motorized camping and hunting opportunities are outside of the 2502 opportunities for those who wish to hunt in the forest. If the forest does Travel Management process. The draft record of decision designates not provide sufficient campsites that are far enough off the roads, approximately 91 miles of motorized trails for full-sized vehicle use that hunters will be discouraged from choosing Tonto National Forest. access 2,750 inventoried existing dispersed camping sites on the Tonto National Forest. These routes currently exist on the ground and

31 Travel Management on the Tonto National Forest

Comment Letter Original Comment Text Forest Service Response Number are likely unauthorized routes that have been used for dispersed camping. More information can be found in the final EIS. For a more detailed description of how these sites were inventoried, see the final Arizona Game and Fish Department report in the project record. We support the addition of social routes to the MVUM system with Compliance with the final Travel Manage Rule is not expected to 2506 open designation until such time that NEPA or Arch surveys dictate resolve all Forest management issues. While management of some other designation. These social routes have been in the Forest motorized access on the Tonto National Forest will include increased system and commonly used by the public for decades. Pulling these management of motorized use across the Forest, it is not meant to social routes out of the system would create a patchwork, completely make the Forest less accessible to the public. The travel management unmanageable trail network where systematic implementation and planning effort is meant to increase the effectiveness of managing ultimate enforcement of the Forest’s plan would be literally impossible. motorized uses to reduce Forest impacts while still allowing multiple We support AZOHV’s soft landing approach where these routes uses across the Forest. User-created routes were created without remain open until such time there is sufficient information to justify Agency authorization, environmental analysis, or public involvement closure and feel this is a reasonable and sound approach that will and do not have the same status as National Forest System roads and greatly aid the acceptance of the plan by the public. trails included in the Forest transportation system. The designations in the draft record of decision do not preclude future analysis and designation of National Forest System roads or trails. For public access, approximately 1,311 miles of designated roads and 2,341 miles of motorized trails will be open, including some of these user- created routes as designated routes. We believe that the changes proposed by AZOHVC and TRAL begin Between draft and final, the alternative C has been further modified to 2506 to address the serious shortage of motorized single track trails in the address comments that were received. Comment received on the draft current plan. The Mesa and Cave District are currently the only areas EIS identified the need to provide motorized trails for motorcycle and that show motorized single track trails and the quantity in the plan is dirt bike use, referred to as single track. The draft record of decision nowhere near sufficient to meet the current demand for this type of designates 109 miles of single-track motorized trails. Under the “Public trail. Comments on the Proposed Rule and Department Responses” section of the 2005 Travel Management Rule (Federal Register, Volume 70, Number 216 1192015, page 68283) states "Since the system of designated routes and areas will change over time, the Department anticipates that local units will publish new motor vehicle use maps annually and update signs as necessary or appropriate." The designated roads, motorized trails, and areas will be reviewed annually. We support the motorized trail concept and believe that collectively we Between draft and final, the alternative C has been further modified to 2506 will need to add width designations/limits to protect trails from address comments that were received. Comment received on the draft expanding from single track width to full size vehicle width over time. EIS identified the need to provide motorized trails for motorcycle and

32 Volume II–Response to Comments

Comment Letter Original Comment Text Forest Service Response Number The comments included make recommendations on an appropriate dirt bike use, referred to as single track. The draft record of decision designation for the trails in ALT C. designates 109 miles of single-track motorized trails. The Travel Management Rule requires designation by class of vehicle and, if needed, time of year. Therefore if a trail is defined as a single-track trail, larger vehicles legally will not be allowed on it. The Tonto National Forest will be working with the public to identify where this may be occurring to prevent trail widening. TRAL believes that any sustainable OHV trail network must have the The Travel Management Rule requires designation by class of vehicle 2510 following: A sufficient quantity (mileage) of trails that are designated and, if needed, time of year. Between draft and final EIS, alternative C for specific user types and that are well-marked A sufficient variety of has been further modified to address comments that were received, trails o Capable of serving a diverse range of user types o Capable of including the need for a variety of opportunities mentioned by the serving a range of technical challenge / ability - from an average commenter. The draft record of decision designates 2,341 miles of weekend recreational user up through a highly skilled/technically motorized trails of varying forms. During the implementation of the advanced user • A well thought out / user designed system that travel management plan this information will be very valuable for the allows users to create a wide variety of scenic and/or technically districts. As volunteers you can help the districts implement the challenging loop rides by linking main trails through multiple connector strategies that will work for each location. Using Adopt-A-Trail trails. The opportunity to enjoy the wide variety of terrain, wildlife and program you mentioned and the draft implementation program, scenic views the forest has to offer. An adopt-a-trail program that uses January 30, 2014, you will be able to assist the Forest in maintaining volunteer labor to establish and maintain the trail system our OHV trail network. A plan should be created that doesn't create a conflict with Comment is an opinion and lacks "supporting reasons for the 2511 communities & residential areas. responsible official to consider" per 36 CFR 218.2. Without more specific information from the commenter, it is difficult to determine the conflicts referred to. Compliance with the final Travel Manage Rule is not expected to resolve all Forest management issues. The travel management planning effort is meant to increase the effectiveness of managing motorized uses to reduce Forest impacts while still allowing multiple uses across the Forest. However, impacts to adjacent landowners were analyzed in the “Recreation” section of chapter 3 of the final EIS. Also that trail in many places is next to homes, the noise, dust, unsafe Comment is an opinion and lacks "supporting reasons for the 2511 issues & trespassing of OHV use has made their homes unpleasant. responsible official to consider" per 36 CFR 218.2. Compliance with We need to have the OHV use where it is not disturbing to homes & the final Travel Manage Rule is not expected to resolve all Forest communities. management issues. The travel management planning effort is meant to increase the effectiveness of managing motorized uses to reduce Forest impacts while still allowing multiple uses across the Forest.

33 Travel Management on the Tonto National Forest

Comment Letter Original Comment Text Forest Service Response Number However, impacts to adjacent landowners were analyzed in the “Recreation” section of chapter 3 of the final EIS. First priority is to be fair to non-motorized users & home owners near Comment is an opinion and lacks "supporting reasons for the 2511 trails that have or may have OHV use. responsible official to consider" per 36 CFR 218.2. Compliance with the final Travel Manage Rule is not expected to resolve all Forest management issues. The travel management planning effort is meant to increase the effectiveness of managing motorized uses to reduce Forest impacts while still allowing multiple uses across the Forest. However, impacts to adjacent landowners were analyzed in the “Recreation” section of chapter 3 of the final EIS. The Houston Mesa Horse Camp needs to have the whole Houston This is outside the scope of designating a motor vehicle system for the 2511 Mesa Trail non-motorized to succeed, along with signage equal to the Tonto National Forest in compliance with the final Travel Management Houston Mesa Campground across the road. Rule. No further response is warranted. Staging areas need to also be placed away from communities for the The draft record of decision does not designate staging areas. The 2511 same reason. Payson OHV Staging and the Travel Management Plan is a separate environmental analysis process. We hope you will submit these comments to any proposed projects considering staging areas. I like the idea of have staging areas with trails that create a loop so The draft record of decision does not designate staging areas. The 2511 there is less desire to go off trail. In many places it could be made Payson OHV Staging and the Travel Management Plan is a separate possible with a short connecting trail to other trails. environmental analysis process. We hope you will submit these comments to any proposed projects considering staging areas. The Staging area suggested on Jim Jones road is a undesirable The draft record of decision does not designate staging areas. The 2511 choice, it's too close to a community & that community already has the Payson OHV Staging and the Travel Management Plan is a separate disturbance of the shooting range noise. environmental analysis process. We hope you will submit these comments to any proposed projects considering staging areas. There are also petroglyphs in that area on the side of the road that The draft record of decision does not designate staging areas. The 2511 may be destroyed by the heavy use of a staging area. Payson OHV Staging and the Travel Management Plan is a separate environmental analysis process. We hope you will submit these comments to any proposed projects considering staging areas. There may be a way that from FR 419 on the west side of Hwy 87 The travel management planning effort is meant to increase the 2511 there could be a connecting trail made to FR 442 to give many miles of effectiveness of managing motorized uses to reduce Forest impacts riding. while still allowing multiple uses across the Forest. The draft record of decision will designate a system for motorized use that will maintain and improve Forest resources so that motorized and non-motorized

34 Volume II–Response to Comments

Comment Letter Original Comment Text Forest Service Response Number Forest visitors can continue to experience and enjoy the Forest. The draft record of decision will not preclude future analysis, construction, or designation of National Forest System roads or trails. The staging area suggested for Mayfield Canyon is another that needs The draft record of decision does not designate staging areas. The 2511 to go somewhere else because of being close to a community. This Payson OHV Staging and the Travel Management Plan is a separate area also makes it difficult to keep OHVs off the Houston Mesa Trail a environmental analysis process. We hope you will submit these PATS trail, which should be non-motorized. comments to any proposed projects considering staging areas. There are much better places to create staging & camping areas that The draft record of decision does not designate staging areas. The 2511 would be a lot more enjoyable for the OHV people. Such as a little Payson OHV Staging and the Travel Management Plan is a separate more east off Hwy 260 on south side of Hwy FR 436, this connects environmental analysis process. We hope you will submit these into many FR that can take an OHV rider south & if a connecting trail comments to any proposed projects considering staging areas. was made to other FR then it would easily create a loop. Also, on the north side of Hwy 260 on FR 365 is a good place for a The draft record of decision does not designate staging areas. The 2511 staging & camping area that has so many possibilities to ride if they go Payson OHV Staging and the Travel Management Plan is a separate up to control road and if maybe make a short connecting trail from FR environmental analysis process. We hope you will submit these 1294 to FR 65 so the OHV traffic won't disturb Tonto Village. comments to any proposed projects considering staging areas. I have not seen the area that is suggested for the staging area south The draft record of decision does not designate staging areas. The 2511 of Pine but I would give the same advice. Payson OHV Staging and the Travel Management Plan is a separate environmental analysis process. We hope you will submit these comments to any proposed projects considering staging areas. We've heard that many OHV people like to go to Pyeatt Draw and that The draft record of decision does not designate staging areas. The 2511 could be where FR 198 could take them out there with a staging area. Payson OHV Staging and the Travel Management Plan is a separate environmental analysis process. We hope you will submit these comments to any proposed projects considering staging areas. Authorize dispersed and safe motorized camping consistent with the The draft record of decision will designate approximately 91 miles of 2512 reasonable enjoyment of safety, privacy, comfort, custom and culture, motorized trails for full-sized vehicle use that access 2,750 inventoried and/or trailers at a distance of 300 feet from the closest legally open existing dispersed camping sites on the Tonto National Forest. These road or trail. Access to dispersed camping sites previously used and routes currently exist on the ground and are likely unauthorized routes established in the local custom and culture as demonstrated by that have been used for dispersed camping. In response to comments tangibles evidences of previous use such as fire pits, improvements, on the draft EIS, the Tonto National Forest Patrol Captain and the etc. is allowed. Arizona Game and Fish Department Wildlife Manager Supervisor (both part of the ID team) indicated that it would be much easier to implement designated “spur” routes to known, inventoried dispersed camping sites instead of corridors of a certain width (either 100 feet or 300 feet). Based on this information and the comments received,

35 Travel Management on the Tonto National Forest

Comment Letter Original Comment Text Forest Service Response Number alternative C was modified to reflect this change. More information can be found in the final EIS. Authorize dispersed recreational shooting. The authorized motorized Non-motorized shooting opportunities are outside of the Travel 2512 dispersed recreational shooting consists of one trip each way from the Management process. The draft record of decision designates motor natural or artificial obvious terrain feature used as a backstop, such as vehicle use, up to one mile on both sides of all designated roads and pit,berth or features similar in their functionality as relates to safe motorized trails, solely for retrieving legally harvested elk and bear for dispersed shooting, to the closest legally open road or trail, regardless all hunts. of distance but not more than one mile, by the most direct route compatible with safety and the preservation of other values such as riparian areas, archeological sites, etc. Retain the suitability for future consideration of new motorized areas The Tonto National Forest is 2,964,308 acres in size. Excluding all 2512 and trails of at least 75% of the Tonto National Forest. designated wilderness areas (totaling 615,855) where motor vehicle use is strictly prohibited, that would leave 79% of the Forest that could potentially be accessed with a motor vehicle. The draft record of decision designates a system for motorized use while maintaining and improving Forest resources so that motorized and non-motorized Forest visitors can continue to experience and enjoy the Forest. The final travel management decision will not preclude future analysis, construction, or designation of National Forest System roads or trails. The travel management plan DE/5 limits dispersed camping to a 100 The draft record of decision will designate approximately 91 miles of 2512 feet corridor on both sides of designated roads and motorized trails motorized trails for full-sized vehicle use that access 2,750 inventoried (Alternative C). Gila County believes that the limitation to a 300 feet existing dispersed camping sites on the Tonto National Forest. These corridor off either side of the edge of designated roads or trails is routes currently exist on the ground and are likely unauthorized routes inadequate because it restricts access to numerous camping sites in that have been used for dispersed camping. In response to comments the Tonto National Forest that have become deeply ingrained in the on the draft EIS, the Tonto National Forest Patrol Captain and the custom and culture of the residents of and visitors to Gila County. Arizona Game and Fish Department Wildlife Manager Supervisor (both part of the ID team) indicated that it would be much easier to implement designated “spur” routes to known, inventoried dispersed camping sites instead of corridors of a certain width (either 100 feet or 300 feet). Based on this information and the comments received, alternative C was modified to reflect this change. More information can be found in the final EIS. For more information about how these sites were inventoried and how the mileage to them was calculated, see the Arizona Game and Fish Department Report for Inventory of Motorized Dispersed Campsites on the Tonto National Forest in the project record.

36 Volume II–Response to Comments

Comment Letter Original Comment Text Forest Service Response Number Gila County therefore believes that the implementation of the Travel Comment is an opinion and lacks "supporting reasons for the 2512 Management Rule would fail to meet the requirements to reasonably responsible official to consider" per 36 CFR 218.2 outside of the above accommodate the culture and custom of the residents of and visitors to submitted comments which have been specifically responded to. No Gila County if such historically popular motorized camping sites were further response warranted. artificially outlawed due to their inaccessibility in a new travel management plan. Gila County believes that authorized dispersed motorized camping In chapter 2 of the final EIS, under alternative C, an inventory of 2512 must allow the parking of motorized vehicles and/or trailers at a existing dispersed sites that were accessible by a motor vehicle was distance of 300 feet from the closest legally open road or trail, AND conducted for the Tonto National Forest. Instead of corridors, the allow access to dispersed camping sites previously used and Forest supervisor decided to designate short spur motorized trails to established in the local custom and culture as demonstrated by sites, some well over 300 feet from existing roads, excluding some in tangibles evidences of previous use such as fire pits, improvements, order to continue to minimize effects of motor vehicle use, as indicated etc. in the draft record of decision. The travel management plan DE/5 does not address specifically The draft record of decision designates a system for motorized use 2512 dispersed shooting. Yet, the Forest Service in its own analysis states: while maintaining and improving Forest resources so that motorized "Ceasing or limiting off-road vehicle use of the ASNFs would limit or and non-motorized Forest visitors can continue to experience and restrict most dispersed recreational shooting to areas along roads enjoy the Forest. The designation of non-motorized shooting open for public use, increasing the risk to human health and safety" opportunities are outside of the Tonto National Forest Travel (Draft Environmental Assessment Second Knoll Shooting Range p. Management process. The draft record of decision designates motor 27). Gila County believes that not every recreational shooter will use vehicle use, up to one mile on both sides of all designated roads and the developed shooting facilities such as the Second Knoll Shooting motorized trails, solely for retrieving legally harvested elk and bear for Range, especially when such facilities are located more than half an all hunts. hour to an hour or more travelling distance. Therefore, Gila County believes that for safety reasons dispersed shooting should be included in the provisions of authorized cross-country travel with the following restrictions: the authorized motorized dispersed recreational shooting consists of one trip each way from the natural or artificial obvious terrain feature used as a backstop, such as pit, berth or terrain feature similar in their functionality as relates to safe dispersed shooting, to the closest legally open road or trail, not more than one mile away, by the most direct route compatible with safety and the preservation of other values such as riparian areas, archeological sites, etc. I am concerned that the proposed Plan will unduly limit opportunities The draft record of decision will designate approximately 91 miles of 2513 for dispersed camping throughout the forest. Specifically, many motorized trails for full-sized vehicle use that access 2,750 inventoried dispersed camping sites are not directly accessible from roads existing dispersed camping sites on the Tonto National Forest. These proposed in the Travel Management Plan. routes currently exist on the ground and are likely unauthorized routes

37 Travel Management on the Tonto National Forest

Comment Letter Original Comment Text Forest Service Response Number that have been used for dispersed camping. In response to comments on the draft EIS, the Tonto National Forest Patrol Captain and the Arizona Game and Fish Department Wildlife Manager Supervisor (both part of the ID team) indicated that it would be much easier to implement designated “spur” routes to known, inventoried dispersed camping sites instead of corridors of a certain width (either 100 feet or 300 feet). Based on this information and the comments received, alternative C was modified to reflect this change. More information can be found in the final EIS. Non-motorized dispersed camping is outside the scope of the travel management process. Forest visitors can travel off of roads and trails via non-motorized means to camp sites. To alleviate this problem, I propose that the rule be amended to allow The draft record of decision will designate approximately 91 miles of 2513 limited travel off designated roads to dispersed camping sites where motorized trails for full-sized vehicle use that access 2,750 inventoried feasible. existing dispersed camping sites on the Tonto National Forest. These routes currently exist on the ground and are likely unauthorized routes that have been used for dispersed camping. In response to comments on the draft EIS, the Tonto National Forest Patrol Captain and the Arizona Game and Fish Department Wildlife Manager Supervisor (both part of the ID team) indicated that it would be much easier to implement designated “spur” routes to known, inventoried dispersed camping sites instead of corridors of a certain width (either 100 feet or 300 feet). Based on this information and the comments received, alternative C was modified to reflect this change. More information can be found in the final EIS. Non-motorized dispersed camping is outside the scope of the travel management process. Forest visitors can travel off of roads and trails via non-motorized means to camp sites. Also, it seems that some of the trails near Houston Mesa Horse Camp Comment lacks "supporting reasons for the responsible official to 2519 are also being changed to allow motorized use. consider" per 36 CFR 218.2 outside of the above submitted comments which have been specifically responded to. Without specific details about which routes the commenter is speaking of, no further response will be forthcoming. The travel management plan is of concern to us because it appears Comment lacks "supporting reasons for the responsible official to 2519 that trails which have been previously designated as non-motorized consider" per 36 CFR 218.2 outside of the above submitted comments and are part of the Payson Area Trails System (PATS) are now going which have been specifically responded to. Without specific details to allow motorized travel. about which routes the commenter is speaking of, no further response will be forthcoming.

38 Volume II–Response to Comments

Comment Letter Original Comment Text Forest Service Response Number Protect trails that are already designated as non-motorized and not let The draft record of decision designates a system for motorized use 2519 them be reassigned to motorized use. If connections need to be made while maintaining and improving Forest resources so that motorized to complete a motorized system, work with local communities for and non-motorized Forest visitors can continue to experience and acceptable options. Consider the safety of non-motorized trail users in enjoy the Forest. The “Recreation” section of the final EIS analyzed this mix. impacts of designating a motorized system on adjacent landowners as well as impacts to non-motorized user groups. These designations will not preclude future analysis, construction, or designation of National Forest System roads or trails. Under the “Public Comments on the Proposed Rule and Department Responses” section of the 2005 Travel Management Rule (Federal Register, Volume 70, Number 216 1192015, page 68283) states "Since the system of designated routes and areas will change over time, the Department anticipates that local units will publish new motor vehicle use maps annually and update signs as necessary or appropriate." The motorized trails will be reviewed annually. This will give all Forest users an opportunity to bring changes to our attention. Discourage designation of motorized trails in close proximity to The draft record of decision designates a system for motorized use 2519 residential areas and communities. Non-motorized use has less impact while maintaining and improving Forest resources so that motorized on the environment and existing neighborhoods. and non-motorized Forest visitors can continue to experience and enjoy the Forest. The recreation section of the final EIS analyzed impacts of designating a motorized system on adjacent landowners as well as impacts to non-motorized user groups. Other than the obvious destruction of the natural resource, those In 36 CFR 212.55(a) “General criteria for designation of National 2520 eroded OHV trails in many places have destroyed the original trail. Forest System roads, National Forest System trails and areas on Once the erosion is so bad that the OHVs cannot use the trail, they National Forest System Lands” states “the responsible officer shall just move over to a new areas and create another erosion site that will consider…the need of maintenance…and the availability of resources eventually end up like the first site. Most of this damage has been for that maintenance and administration.” After these roads, trails, and done in the last 20 years What will it be like after the next 20 years areas are designated, motor vehicle use, including the class of vehicle with no hope for resource repair? and time of year, not in accordance with these designations is prohibited by 36 CFR 261.13. Volunteers have enabled the Tonto National Forest to accomplish much needed trail maintenance, signing, fence construction, and visitor contacts with fewer dollars. Grants and other sources of funding would continue to be a viable option for increasing the Forest’s ability to maintain the motorized and non-motorized trail system.

39 Travel Management on the Tonto National Forest

Comment Letter Original Comment Text Forest Service Response Number We are very pleased that this area east of Sunflower has been The draft record of decision designates a system for motorized use 2520 restricted to "administrative use only" and some unauthorized trails are while maintaining and improving Forest resources so that motorized recommended for decommissioning. This is a unique area within and non-motorized Forest visitors can continue to experience and Sycamore Creek and The American Trail. Hopefully this area can enjoy the Forest, though designation of non-motorized opportunities remain non-motorized. For some of us that like to hike, ride horses, are outside of the scope of the travel management process. Thank etc. it is really nice to have a non-motorized area like this because you for your support of the decommissioning of routes and routes we've lost so many horseback trails to OHVs in the Rolls and designated as administrative use only in this area. Sycamore Creek areas. Regarding the use of riparian areas as a main artery for the OHVs to The draft record of decision does not designate staging areas. 2520 access the upland county. We are mostly restricted from grazing in Designation of staging areas is a separate environmental analysis riparian areas. If grazing is permitted, it is only certain times of year. process. We applied the minimization criteria identified in 36 CFR Yet for example, in the "Mesquite Wash Staging Area'', the only way 212.55(b) to minimize damage to soil, watershed, vegetation, other you can exit the staging area without crossing HWY 87 is to go into Forest resources, and disruption of wildlife habitats. Eliminating all Mesquite Wash which leads to Sycamore Creek. Same forest, same routes in close proximity to stream and river channels is not a viable natural resource, but two users treated differently. alternative. Some routes are important routes needed for connectivity, and for access to private land, administrative sites, permitted uses, trailheads, etc., and many crossings are hardened or have culverts or bridges. The analysis of all alternatives for stream crossings can be found in the “Hydrological Resources” section of chapter 3 in the final EIS and that report in the project record. There is a status of users acknowledged by the Forest Service, those granted occupancy or use of National Forest System lands and resources. These uses are identified in the Multiple Use and Sustained Yield Act and are part of the National Forest Management Act. They are granted administrative use only as a means to access their improvements and infrastructure in locations where public use is restricted, or to protect their improvements and infrastructure. And, while ranchers and permittees may have more access in such cases, they are not entitled to use such access into areas where the public cannot go for reasons other than that required for the administration of their special use. Furthermore, impacts from grazing activity as compared to impacts of designating a motorized system on the Forest is outside of the scope of this analysis. However, the effects of grazing activity on the Forest were considered in the cumulative effects analysis in the final EIS. For too many years, unregulated cross-country motorized travel has The background of the Travel Management Rule (Federal Register, 2521 led to trail and road development at densities that are both Volume 70, Number 216 1192015, pages 68264 and 68265) gives the

40 Volume II–Response to Comments

Comment Letter Original Comment Text Forest Service Response Number economically and ecologically unsustainable. Many of these routes same issues you mention as the need for the Travel Management were user-created without any sort of planning for resource protection Rule. An unauthorized route is not a National Forest System road or or wildlife conservation. Further, because many of the roads on the trail. It is a route that is not "A road or trail wholly or partly within or Tonto were unplanned and created largely as a result of unrestricted adjacent to and serving the National Forest System that the Forest motorized use, the social and biological impacts of such use were Service determines is necessary for the protection, administration, and never evaluated. Accordingly, we fully support the Forest Service's utilization of the National Forest System and the use and development efforts to identify and decommission duplicative and unsustainable of its resources" (36 CFR 212.1). User-created roads and motorized routes in the forest trails may be identified through public involvement and considered in the designation process. After public consideration and appropriate site-specific environmental analysis, some user-created routes may be designated for motor vehicle use pursuant to 36 CFR 218 § 212.51 of the final rule. These routes would become National Forest System roads or National Forest System motorized trails and would be included in a Forest transportation atlas and reflected on a motor vehicle use map. We considered approximately 672 miles of unauthorized routes. Considerations to include a route or a portion of a route in our route system included potential effects to resources. We also understand the demand for areas that allow cross country Comment is an opinion and lacks "supporting reasons for the 2521 travel and support limiting these uses to the designated areas listen in responsible official to consider" per 36 CFR 218.2. In the draft record the plan (p 39). of decision, motorized travel off designated routes would be limited to four areas. More information can be found in the final EIS. While we understand the need to protect resources with limits on The draft record of decision will designate approximately 91 miles of 2521 dispersed camping, the USFS should retain popular and sustainable motorized trails for full-sized vehicle use that access 2,750 inventoried dispersed site's outside of the limited area where appropriate by existing dispersed camping sites on the Tonto National Forest. These signing·and designating them as open. routes currently exist on the ground and are likely unauthorized routes that have been used for dispersed camping. In response to comments on the draft EIS, the Tonto National Forest Patrol Captain and the Arizona Game and Fish Department Wildlife Manager Supervisor (both part of the ID team) indicated that it would be much easier to implement designated “spur” routes to known, inventoried dispersed camping sites instead of corridors of a certain width (either 100 feet or 300 feet). Based on this information and the comments received, alternative C was modified to reflect this change. More information can be found in the final EIS. Non-motorized dispersed camping is outside the scope of the travel management process. Forest visitors can travel off of roads and trails via non-motorized means to camp sites.

41 Travel Management on the Tonto National Forest

Comment Letter Original Comment Text Forest Service Response Number The assumption that enforcement will reduce the impacts of motorized The assumption that enforcement will reduce the impacts is a 2472 uses on Wilderness areas (DEIS at 127) is a false assumption completely valid assumption. It is also well documented that the because the lack of enforcement is well documented in the DEIS impacts we have seen would be even worse today if it were not for through the identification of hundreds of miles of illegal motorized enforcement efforts. It does not mean that we won't have violations routes throughout the TNF. All analysis based on this assumption and/or issues though. After these roads, trails, and areas are should be revised to reflect the documented fact that motorized vehicle designated, motor vehicle use, including the class of vehicle and time uses do not follow motor vehicle use designations, even in wilderness of year, not in accordance with these designations is prohibited by 36 areas, and the TNF has limited enforcement capability. CFR 261.13. Motor vehicle use off designated roads and trails and outside designated areas is prohibited by 36 CFR 261.13” (36 CFR 212.50(a)). Per 40 CFR 1501.7, alternatives are developed from significant issues raised during scoping. Enforcement was not identified as a significant issue as a result of the scoping process. Furthermore, enforcement strategies will vary as a result of the implementation of the final Travel Management Rule, and does not vary by alternative. As outlined in the Law Enforcement report summarized in the final EIS, the best chance of successfully enforcing any measure, regardless of the issue, is for the majority to understand the importance of the measure and thus want to comply. As it relates to the travel management planning, successful enforcement requires, at a minimum: (1) The majority of the public to understand the importance of the management plan, the rules of the management plan and have a desire to comply with those rules. The number of Forest Service law enforcement is small in comparison to the number of Forest visitors. Which means it is extremely difficult to educate the public in the field and achieve compliance. (2) State and local agencies must also understand the importance of the plan and be willing and active partners in implementing the plan. The overarching strategy for enforcement is also outlined in the “Law Enforcement” section in chapter 3 of the final EIS. Because the Payson project was designed with the ongoing travel Cumulative effects analysis is found for each resource in chapter 3 of 2472 management project and proposals for designated routes in mind, the the final EIS. impacts from both projects should be analyzed within a cumulative effects analysis for both actions. Protect the Payson Area Trail System, including Houston Loop Trail, The purpose of this analysis is to designate motor vehicle use on the 2519 Monument Peak Trail Boulders Trail (north and south), Cypress Trail, Tonto National Forest. Houston Loop Trail has been designated Peach Orchard Trail and Loop, Round Valley Trail and American motorized to allow access to the rest of the trails (Monument,

42 Volume II–Response to Comments

Comment Letter Original Comment Text Forest Service Response Number Gulch Trail and any trails on Trail Maps #850 and #852 already Boulders, and Cypress). Peach Orchard Trail provides for motorized designated as non-motorized. Work with local horsemen and other trail opportunity that connects to Main Street in the town of Payson. non-motorized users on this issue. Round Valley Trail provides for motorized loop recreation, and American Gulch Trail provides access to hunting, recreation, and natural resource survey opportunities. Any plan that does not bar HOV from sensitive trails such as the Comment is an opinion and lacks "supporting reasons for the 24 Boulder Loop, Cypress, Monument Peak is a disgraceful disservice. responsible official to consider" per 36 CFR 218.2. Houston Loop Trail has been designated motorized to allow access to the rest of the trails (Monument, Boulders, and Cypress). Peach Orchard Trail provides for motorized trail opportunity that connects to Main Street in the town of Payson. Round Valley Trail provides for motorized loop recreation, and American Gulch Trail provides access to hunting, recreation, and natural resource survey opportunities.

43 Travel Management on the Tonto National Forest

Wilderness, Wild and Scenic Rivers, Inventoried Roadless Areas, and Special Management Comment Letter Original Comment Text Forest Service Response Number In Insert 3 and on the main map, routes 1521 and 401A are shown as Per the legal wilderness description, both of these routes are outside 5 entering the Four Peaks Wilderness area. This is inconsistent with the of the designated wilderness area as they are buffered 33 feet on both regulations of a wilderness area. I am assuming that the routes are sides from center line. However, at the scale that the alternative maps correct and that the map should be updated with these routes being are presented, it is impossible to show this visually. All maps and GIS shown as a "cherry stem" into the wilderness area. data are a visual representation and have a level of inaccuracy at less than 5%. The roads listed in Table 1 of the Special Areas specialist report at The draft record of decision designates for decommissioning the 2472 page 10 and 11 (and pasted below) must all be closed, following routes within wilderness: Forest Service 203B and 487B. decommissioned and not considered for designation as motorized These will be prioritized for decommissioning based on funding and routes in any alternative. To designate any of these routes as system logistics. However the following routes will be designated as permitted routes would, as the Forest Service is well aware, violate the use only with road use permits: FSR 406B, 487A, and 567B will be Wilderness Act as there cannot be any permanent roads in designated closed to public use and travel where they enter the wilderness. Use Wilderness Areas. will continue to be permitted to only the private inholding landowners in a manner that does not preclude access to the land. Section 1323(a) of ANILCA provides property owners within the boundaries of the National Forest System certain rights of access across National Forest System lands. According to the terms of ANILCA, such access shall be “subject to such terms and conditions as the Secretary of Agriculture may prescribe,” and “as the Secretary deems adequate to secure to the owner the reasonable use and enjoyment thereof: Provided, That such owner comply with rules and regulations applicable to ingress and egress to or from the National Forest System” (16 U.S.C. 3210(a)). “While ANILCA provides certain rights to property owners, those rights are subject to such reasonable terms and conditions as the Forest Service may prescribe in a written authorization. Some property owners also may possess reserved or outstanding rights-of- way or other rights providing access across National Forest System lands, which may or may not require a written authorization from the Forest Service. Those rights must be recognized under § 212.55(d). To the extent other provisions of ANILCA may address rights for motor vehicle access, they are covered by §212.55(d)(1), which requires that the responsible official recognize valid existing rights in making designations under the final rule” (Federal Register, Volume 70, Number 216, page 68282). Within the project record, located at the Supervisor’s Office in Phoenix, Arizona, is documentation for the

44 Volume II–Response to Comments

Comment Letter Original Comment Text Forest Service Response Number current road use permits for FSR 406B and 567B. From the intersection with FSR 3456 until it encounters the southeastern boundary of the Mazatzal Wilderness boundary, FSR 393 is designated as a motorized trail. For the 0.62 miles that 393 is within the Mazatzal Wildness boundary, FSR 393 is designated administrative use only in compliance with the special use permit issued to APS in 2012, as well as for necessary endangered species work. Where FSR 393 exits the wilderness boundary near the northwest corner of section 2 until it intersection with FSR 627, it is designated as a motorized trail. Both the Wilderness Act of 1964 (P.L. 88-577) and the Arizona Wilderness Act of 1984 (P.L. 98-406) allow for this type of non-conforming use within the wilderness. In 1961, the Tonto National Forest authorized APS, via a special use permit, to maintain the Four Corners to Pinnacle Peak 345kV Power Transmission Line. As part of the special use permit, APS was authorized motor vehicle access to maintain this transmission line. One such route named in the original permit is FSR 393, which originates near the Verde River southwest of Bartlett Lake and follows the transmission line northwesterly until FSR 393 connects with FSR 627 south of Cross Ranch—FSR 627 was originally State Highway 87 before it was realigned by the Arizona Department of Transportation. With passage of the Wilderness Act in 1964, the legal boundary for the Mazatzal Wilderness was drawn incorporating sections of both FSR 393 and part of the transmission line within the boundary—the maps used for the legal mapping where early 1950s quadrangle maps. A legal description with maps, prepared in 1970 that superseded the previous legal description, still showed both a portion of FSR 393 and the transmission line within the wilderness boundary. With the passage of the Arizona Wilderness Act of 1984, an updated legal description and maps were produced, superseding previous legal descriptions. In this version, the eastern boundary where is connects with the southern boundary was moved and the transmission lines where no longer within the designated wilderness boundary; however, the road continues to be within the wilderness boundary. All routes that are located within designated wilderness boundaries The draft record of decision designates for decommissioning the 2472 should be closed and prioritized for decommissioning. following routes within wilderness: Forest Service 203B and 487B. These will be prioritized for decommissioning based on funding and

45 Travel Management on the Tonto National Forest

Comment Letter Original Comment Text Forest Service Response Number logistics. However the following routes will be designated as permitted use only with road use permits: FSR 406B, 487A, and 567B will be closed to public use and travel where they enter the wilderness. Use will continue to be permitted to only the private inholding landowners in a manner that does not preclude access to the land. Section 1323(a) of ANILCA provides property owners within the boundaries of the National Forest System certain rights of access across National Forest System lands. According to the terms of ANILCA, such access shall be “subject to such terms and conditions as the Secretary of Agriculture may prescribe,” and “as the Secretary deems adequate to secure to the owner the reasonable use and enjoyment thereof: Provided, That such owner comply with rules and regulations applicable to ingress and egress to or from the National Forest System” (16 U.S.C. 3210(a)). “While ANILCA provides certain rights to property owners, those rights are subject to such reasonable terms and conditions as the Forest Service may prescribe in a written authorization. Some property owners also may possess reserved or outstanding rights-of- way or other rights providing access across National Forest System lands, which may or may not require a written authorization from the Forest Service. Those rights must be recognized under § 212.55(d). To the extent other provisions of ANILCA may address rights for motor vehicle access, they are covered by §212.55(d)(1), which requires that the responsible official recognize valid existing rights in making designations under the final rule” (Federal Register, Volume 70, Number 216, page 68282). Within the project record, located at the Supervisor’s Office in Phoenix, Arizona, is documentation for the current road use permits for FSR 406B and 567B. From the intersection with FSR 3456 until it encounters the southeastern boundary of the Mazatzal Wilderness boundary, FSR 393 is designated as a motorized trail. For the 0.62 miles that 393 is within the Mazatzal Wildness boundary, FSR 393 is designated administrative use only in compliance with the special use permit issued to APS in 2012, as well as for necessary endangered species work. Where FSR 393 exits the wilderness boundary near the northwest corner of section 2 until it intersection with FSR 627, it is designated as a motorized trail. Both the Wilderness Act of 1964 (P.L. 88-577) and the Arizona Wilderness Act of 1984 (P.L. 98-406) allow

46 Volume II–Response to Comments

Comment Letter Original Comment Text Forest Service Response Number for this type of non-conforming use within the wilderness. In 1961, the Tonto National Forest authorized APS, via a special use permit, to maintain the Four Corners to Pinnacle Peak 345kV Power Transmission Line. As part of the special use permit, APS was authorized motor vehicle access to maintain this transmission line. One such route named in the original permit is FSR 393, which originates near the Verde River southwest of Bartlett Lake and follows the transmission line northwesterly until FSR 393 connects with FSR 627 south of Cross Ranch—FSR 627 was originally State Highway 87 before it was realigned by the Arizona Department of Transportation. With passage of the Wilderness Act in 1964, the legal boundary for the Mazatzal Wilderness was drawn incorporating sections of both FSR 393 and part of the transmission line within the boundary—the maps used for the legal mapping where early 1950s quadrangle maps. A legal description with maps, prepared in 1970 that superseded the previous legal description, still showed both a portion of FSR 393 and the transmission line within the wilderness boundary. With the passage of the Arizona Wilderness Act of 1984, an updated legal description and maps were produced, superseding previous legal descriptions. In this version, the eastern boundary where is connects with the southern boundary was moved and the transmission lines where no longer within the designated wilderness boundary; however, the road continues to be within the wilderness boundary. The analysis of the action alternatives (all of which allow designation This comment is an opinion and lacks specific "supporting reasons for of motorized routes in designated Wilderness) found in Table 2 of the the responsible official to consider" per 36 CFR 218.2. However, the Special Areas specialist report states that reducing the number of following routes will be designated as administrative use only with road miles of roads in Wilderness would have the potential to reduce effects use permits for the following route with explanation included per 36 but should, for every alternative, state only that designating any CFR 212.55 (e) “Wilderness areas and primitive areas. National Forest motorized route in designated Wilderness will violate the Wilderness System roads, National Forest System trails, and areas on National Act and cannot be permitted. This is true for all alternatives and all Forest System lands in wilderness areas or primitive areas shall not be resources analyzed. designated for motor vehicle use pursuant to this section, unless, in the case of wilderness areas, motor vehicle use is authorized by the applicable enabling legislation for those areas”: FSR 406B, 487A, and 567B will be closed to public use and travel where they enter the wilderness. Use will continue to be permitted to only the private inholding landowners in a manner that does not preclude access to the land. Section 1323(a) of ANILCA provides property owners within the

47 Travel Management on the Tonto National Forest

Comment Letter Original Comment Text Forest Service Response Number boundaries of the National Forest System certain rights of access across National Forest System lands. According to the terms of ANILCA, such access shall be “subject to such terms and conditions as the Secretary of Agriculture may prescribe,” and “as the Secretary deems adequate to secure to the owner the reasonable use and enjoyment thereof: Provided, That such owner comply with rules and regulations applicable to ingress and egress to or from the National Forest System” (16 U.S.C. 3210(a)). “While ANILCA provides certain rights to property owners, those rights are subject to such reasonable terms and conditions as the Forest Service may prescribe in a written authorization. Some property owners also may possess reserved or outstanding rights-of-way or other rights providing access across National Forest System lands, which may or may not require a written authorization from the Forest Service. Those rights must be recognized under § 212.55(d). To the extent other provisions of ANILCA may address rights for motor vehicle access, they are covered by §212.55(d)(1), which requires that the responsible official recognize valid existing rights in making designations under the final rule” (36 CFR 212). Within the project record, located at the Supervisor’s Office in Phoenix, Arizona, is documentation for the current road use permits for FSR 406B and 567B. From the intersection with FSR 3456 until it encounters the southeastern boundary of the Mazatzal Wilderness boundary, FSR 393 is designated as a motorized trail. For the 0.62 miles that 393 is within the Mazatzal Wildness boundary, FSR 393 is designated administrative use only in compliance with the special use permit issued to APS in 2012. Where FSR 393 exits the wilderness boundary near the northwest corner of section 2 until it intersection with FSR 627, it is designated as a motorized trail. Both the Wilderness Act of 1964 (P.L. 88-577) and the Arizona Wilderness Act of 1984 (P.L. 98- 406) allow for this type of non-conforming use within the wilderness. In 1961, the Tonto National Forest authorized APS, via a special use permit, to maintain the Four Corners to Pinnacle Peak 345kV Power Transmission Line. As part of the special use permit, APS was authorized motor vehicle access to maintain this transmission line. One such route named in the original permit is Forest Service Road (FSR) 393, which originates near the Verde River southwest of Bartlett

48 Volume II–Response to Comments

Comment Letter Original Comment Text Forest Service Response Number Lake and follows the transmission line northwesterly until FSR 393 connects with FSR 627 south of Cross Ranch—FSR 627 was originally State Highway 87 before it was realigned by the Arizona Department of Transportation. With passage of the Wilderness Act in 1964, the legal boundary for the Mazatzal Wilderness was drawn incorporating sections of both FSR 393 and part of the transmission line within the boundary—the maps used for the legal mapping where early 1950s quadrangle maps. A legal description with maps, prepared in 1970 that superseded the previous legal description, still showed both a portion of FSR 393 and the transmission line within the wilderness boundary. With the passage of the Arizona Wilderness Act of 1984, an updated legal description and maps were produced, superseding previous legal descriptions. In this version, the eastern boundary where is connects with the southern boundary was moved and the transmission lines where no longer within the designated wilderness boundary; however, the road continues to be within the wilderness boundary. There is no cumulative effects analysis of the impacts to quiet The commenter is correct stating that there is no analysis of “quiet 2472 recreation in Wilderness. The TNF should consider the impacts to recreation” for the wilderness. Section 2(a) of the Wilderness Act visitor use patterns from activities elsewhere on the TNF and nearby states that federal agencies will manage designated wilderness for National Forests. The TNF should also consider other activities “the preservation of their wilderness character.” According to section approved and unapproved--which occur or are likely to occur in the 2(c) of the Act and the Arthur Carhart National Wilderness Training TNF and which would impact recreational users. Center (the organization responsible for much of the Federal wilderness training), the four characteristics used in the final Wilderness, Wild and Scenic Rivers, Inventoried Roadless Areas, and Special Management Areas report analyzes the effects of travel management designation to designated wilderness areas on the Tonto National Forest. The fourth characteristic, “outstanding opportunities for solitude or a primitive and unconfined type of recreation” likely has the closest relationship for what the commenter is requesting. Furthermore, the cumulative effects to designated wilderness associated with the designation of a motor vehicle use system is in the final Wilderness, Wild and Scenic Rivers, Inventoried Roadless Areas, and Special Management Areas report and summarized in the final EIS. The final EIS analyzes the effects of designating a motor vehicle system on the Tonto National Forest. Other effects to recreation, were appropriate for the cumulative effects analysis, as well as an added

49 Travel Management on the Tonto National Forest

Comment Letter Original Comment Text Forest Service Response Number analysis for competing user groups, are found in the same final report. All other activities are outside the scope of this analysis. Illegal motorized trespass is known to occur into the Mazatzal and Salt As stated in chapter 3 of the final EIS, “In order to understand the 2472 River Wilderness Areas. DEIS at 129, Table 37. However, there is no contribution of past actions to the effects of the proposed action and information on how the effects of past illegal motorized intrusions have alternatives, this analysis relies on current environmental conditions as effected or degraded Wilderness areas or experiences. a proxy for the impacts of past actions.” As such, the final “Wilderness, Wild and Scenic Rivers, Inventoried Roadless Areas, and Special Management Areas” sections analyze the effects of past and current motorized use under alternative A, which indicates that several wilderness areas, including the Mazatzal and Salt River, have evidence of illegal motor vehicle trespass. In addition, the effects of this type of activity are analyzed in the report. Continuing to allow dispersed motorized camping in this corridor would This comment is an opinion and lacks specific "supporting reasons for 2472 be in contravention of the Verde Wild and Scenic River Management the responsible official to consider" per 36 CFR 218.2. The Verde Plan, the Wild and Scenic Rivers Act, and Forest Service policy, and River has both a designated wild section, which is within the Mazatzal the TMR. Wilderness, and designated scenic section, which is north if the wilderness. According to the Verde Wild and Scenic River Comprehensive River Management Plan (2004), “Motor vehicle use shall occur only on roads and locations designated for this use. No new roads shall be built in the VWSR” (page 19). As shown in chapter 3 of the final EIS, “Wilderness, Wild and Scenic Rivers, Inventoried Roadless Areas, and Special Management Area” section, there will be four spur routes, designated as full-sized motor vehicle trails, within the corridor of the scenic section of the Verde, totaling less than 0.1 mile. Dispersed motorized camping should not occur within the Verde River This comment is an opinion and lacks specific "supporting reasons for 2472 Corridor. We support the elimination of access for motorized dispersed the responsible official to consider" per 36 CFR 218.2. The Verde camping in the corridor, as included in Alternative B. Motorized River has both a designated wild section, which is within the Mazatzal dispersed camping on the TNF, especially in other areas near the Wilderness, and designated scenic section, which is north if the Verde River, has resulted in destruction and degradation of numerous wilderness. According to the Verde Wild and Scenic River other river corridors and riparian areas. Comprehensive River Management Plan (2004), “Motor vehicle use shall occur only on roads and locations designated for this use. No new roads shall be built in the VWSR” (page 19). As shown in chapter 3 of the final EIS, “Wilderness, Wild and Scenic Rivers, Inventoried Roadless Areas, and Special Management Area” section, there will be four spur routes, designated as full-sized motor vehicle trails, within

50 Volume II–Response to Comments

Comment Letter Original Comment Text Forest Service Response Number the corridor of the scenic section of the Verde, totaling less than 0.1 mile. The DEIS states that a Comprehensive River Management Plan This comment is an opinion and lacks specific "supporting reasons for 2472 (CRMP) for the Fossil Creek Wild and Scenic River was due to be the responsible official to consider" per 36 CFR 218.2. Management of completed by Spring 2014. However, this Plan thus far has not been the Fossil Creek area that the commenter refers to has been completed. The failure to complete this plan is a violation of the Wild delegated to the Coconino National Forest and they will administer the and Scenic Rivers Act, 16 U.S.C. § 1274(d) and should be disclosed Fossil Creek Wild and Scenic River corridor within the boundaries of in the body of the DEIS. Furthermore, this section of the DEIS should the Tonto National Forest. As such, designation of motor vehicle use be updated to reflect the current status of the CRMP, including a will be decided in a separate environmental analysis by a line officer revised timeline for the completion of the CRMP. Additionally, Table from the Coconino National Forest in compliance with the National 38 discusses Motorized Dispersed Camping Opportunities within the Environmental Policy Act. Forest Service Road (FSR) 708, west of the Wild and Scenic River Segments on the Tonto, however it discusses locked gate identified in closure Order Number 12-15-256 and all the cumulative motorized opportunities for both wild and scenic river routes stemming from the closed portion of this road will be designated segments, instead of discussing the motorized opportunities for each administrative use only until such time as the Coconino National segment. The Forest Service should discuss the motorized activity Forest makes a decision for the Fossil Creek corridor. Analysis of allowed within each individual wild and scenic river segment, instead Fossil Creek, as it relates to motor vehicle route and area designation of looking at the cumulative motorized opportunities across both on the Tonto National Forest, can be found in the cumulative effects segments. section of the Recreation report in the final EIS. Additionally, although there is no final Comprehensive River This comment is an opinion and lacks specific "supporting reasons for 2472 Management Plan for the Fossil Creek Wild and Scenic River, the the responsible official to consider" per 36 CFR 218.2. Management of Forest Service still has an obligation to ensure that it is not degrading the Fossil Creek area that the commenter refers to has been any of the Outstandingly Remarkable Values of the Fossil Creek delegated to the Coconino National Forest and they will administer the corridor on the Tonto. The Forest Service should disclose what Fossil Creek Wild and Scenic River corridor within the boundaries of Outstandingly Remarkable Values exist for the Fossil Creek corridor, the Tonto National Forest. As such, designation of motor vehicle use even if in draft form, and also discuss how it will preserve, protect, and will be decided in a separate environmental analysis by a line officer enhance them. Failure to do so violates both the Wild and Scenic from the Coconino National Forest in compliance with the National Rivers Act as well as NEPA Environmental Policy Act. Forest Service Road (FSR) 708, west of the locked gate identified in closure Order Number 12-15-256 and all routes stemming from the closed portion of this road will be designated administrative use only until such time as the Coconino National Forest makes a decision for the Fossil Creek corridor. Analysis of Fossil Creek, as it relates to motor vehicle route and area designation on the Tonto National Forest, can be found in the cumulative effects section of the Recreation report in the final EIS. Finally, should the Forest Service complete the CRMP for the Fossil This comment is an opinion and lacks specific "supporting reasons for 2472 Creek Wild and Scenic River before the publication of this the responsible official to consider" per 36 CFR 218.2. Management of

51 Travel Management on the Tonto National Forest

Comment Letter Original Comment Text Forest Service Response Number Environmental Impact Statement, the Forest Service must disclose its the Fossil Creek area that the commenter refers to has been contents, as well las discuss how it will meet the management delegated to the Coconino National Forest and they will administer the objectives of the CRMP, as well as preserve, protect, and enhance the Fossil Creek Wild and Scenic River corridor within the boundaries of Outstandingly Remarkable Values for the Fossil Creek corridor. the Tonto National Forest. As such, designation of motor vehicle use will be decided in a separate environmental analysis by a line officer from the Coconino National Forest in compliance with the National Environmental Policy Act. Forest Service Road (FSR) 708, west of the locked gate identified in closure Order Number 12-15-256 and all routes stemming from the closed portion of this road will be designated administrative use only until such time as the Coconino National Forest makes a decision for the Fossil Creek corridor. Analysis of Fossil Creek, as it relates to motor vehicle route and area designation on the Tonto National Forest, can be found in the cumulative effects section of the Recreation report in the final EIS. We direct the Forest Service to review Appendix G, in which we Appendix G that the commenter refers, incorrectly labeled appendix H 2472 address distinct potential Wild and Scenic segments and the in what was provided, refers to creek and river segments that were motorized routes that affect them individually, with specific identified as potential for wild and scenic river status in the Resource recommendations as to designation or closure. Information report from 1993. Nothing in the Wild and Scenic Rivers Act of 1968 precludes access associated with motor vehicle use. Section 2(b) of the Act even stipulates the inclusion of roads and trails for access within certain types of potential river segments. Furthermore, “motorized travel on land or water is generally permitted in wild, scenic, and recreational river areas, but will be restricted or prohibited where necessary to protect the values for which the river area was designated” (Federal Register, Volume 47, Number 173, 1982, page 39459). Parker Creek: The Sierra Ancha Experimental Forest authority is shared between the Tonto National Forest and the research station. A station employee has reviewed Forest Service Road 488 and all other routes designated as open to the public or for administrative use only and determined that these routes are necessary to conduct the scientific research for which the experimental forest was designated. Canyon Creek: All routes within the indicated area of the appendix are designated for decommissioning, except for the following two routes. Forest Service Road (FSR) 2234 is designated for administrative use only as it provides access for maintenance of a wildlife water tank.

52 Volume II–Response to Comments

Comment Letter Original Comment Text Forest Service Response Number FSR 2242 is designated for administrative use only to provide access for vegetation management projects. Upper Verde River: Comment addresses illegal motor vehicle use. This project is to designate a system for motor vehicle use across the Forest. No additional routes are being designated that would encourage this type of illegal activity. Specifically, how the Tonto National Forest will implement and enforce the final Travel Management Decision is outside the scope of this analysis. The Tonto National Forest has already developed a draft implementation strategy to address many, if not all of these issues (http://data.ecosystem- management.org/nepaweb/fs-usda-pop.php?project=28967. Spring Creek: Since FSR 484 already existed when Spring Creek was potentially listed, and this route continues to have no effect to the outstandingly remarkable values that this section was originally considered for. Furthermore, this route enables the public to access this river segment, which was considered as potential recreational. Upper Salt River: Comment addresses illegal motor vehicle use. This project is to designate a system for motor vehicle use across the Forest. Specifically, how the Tonto National Forest will implement and enforce the final Travel Management Decision is outside the scope of this analysis. The Tonto National Forest has already developed a draft implementation strategy to address many, if not all of these issues (http://data.ecosystem-management.org/nepaweb/fs-usda- pop.php?project=28967. Lower Salt River and East Verde River: Comments simply supports the designation for the potential segment. Cherry Creek: FR 203B and FR 2812 will be designated as decommissioned as comment requests. FSR 2812 they say has moved locations from section 28 in the wilderness to section 27 in the inventoried roadless area since the potential evaluation was conducted. This can be attributed to newer geospatial information or incorrect mapping. We support eliminating motorized dispersed camping opportunities This comment is an opinion and lacks specific "supporting reasons for 2472 within all potential wild and scenic river corridors. Alternative B comes the responsible official to consider" per 36 CFR 218.2. The draft record closest to this goal. All other alternatives would allow thousands of of decision designates “spur” routes to known, inventoried dispersed camping sites instead of corridors. This is described in chapter 2 of the

53 Travel Management on the Tonto National Forest

Comment Letter Original Comment Text Forest Service Response Number acres of corridors to be open to motorized uses, ensuring continued final EIS under alternative C. Nothing in the Wild and Scenic Rivers destruction. Act of 1968 precludes access associated with motor vehicle use. Section 2(b) of the Act even stipulates the inclusion of roads and trails for access within certain types of potential river segments. Furthermore, “motorized travel on land or water is generally permitted in wild, scenic, and recreational river areas, but will be restricted or prohibited where necessary to protect the values for which the river area was designated” (Federal Register, Volume 47, Number 173, 1982, page 39459). The analysis of effects to eligible rivers from route designation can be found in the “Wilderness, Wild and Scenic Rivers, Inventoried Roadless Areas, and Special Management Areas” section of chapter 3 of the final EIS. The table on page 22 of the Special Areas Report has several errors These sections of potential creeks and rivers that are referred to by the in it: Spring Creek has a wild section which Tonto National Forest has commenter are not analyzed in the final Wilderness, Wild and Scenic not listed. This is segment #2.Workman Creek has a wild section Rivers, Inventoried Roadless Areas, and Special Management Area which Tonto National Forest has not listed. This is segment #2. The report, as they are within a currently designated wilderness area and East Verde River has a scenic section which Tonto National Forest as such, no motorized routes or areas are being designated in or near hasn’t listed. This is segment #3. these sections. Only sections outside wilderness areas are being analyzed as section title in the report indicates: “Potential Wild and Scenic Rivers Outside of Wilderness.” Identification of properly defined quarter-mile corridors around This comment is an opinion and lacks specific "supporting reasons for 2472 designated and potential Wild and Scenic rivers, correction of such in the responsible official to consider" per 36 CFR 218.2. Per 40 CFR the DEIS, and proper analysis of impacts to Wild and Scenic Rivers Section 1502.24, all of the analysis for the final EIS is based on the based on this correction. best available scientific information, which is used in a manner that is defined and can be replicated using the same methodology. Motorized dispersed camping areas should be eliminated in all Wild This comment is an opinion and lacks specific "supporting reasons for 2472 and Scenic and potential Wild and Scenic river corridors. the responsible official to consider" per 36 CFR 218.2. The draft record of decision designates “spur” routes to known, inventoried dispersed camping sites. This is described in chapter 2 of the final EIS under alternative C. Nothing in the Wild and Scenic Rivers Act of 1968 precludes access associated with motor vehicle use. Section 2(b) of the Act even stipulates the inclusion of roads and trails for access within certain types of potential river segments. Furthermore, “motorized travel on land or water is generally permitted in wild, scenic, and recreational river areas, but will be restricted or prohibited where necessary to protect the values for which the river area was

54 Volume II–Response to Comments

Comment Letter Original Comment Text Forest Service Response Number designated” (Federal Register, Volume 47, Number 173, 1982, page 39459). The analysis of effects to eligible rivers from route designation can be found in the “Wilderness, Wild and Scenic Rivers, Inventoried Roadless Areas, and Special Management Areas” section of chapter 3 of the final EIS. The TNF should supplement discussion of cumulative effects from This comment is an opinion and lacks specific "supporting reasons for 2472 travel management planning on designated and potential Wild and the responsible official to consider" per 36 CFR 218.2. Nothing in the Scenic rivers and corridors, including how all alternatives and any final Wild and Scenic Rivers Act of 1968 precludes access associated with decision will impact future management and potential for designation motor vehicle use. Section 2(b) of the Act even stipulates the inclusion for all corridors. of roads and trails for access within certain types of potential river segments. Furthermore, “motorized travel on land or water is generally permitted in wild, scenic, and recreational river areas, but will be restricted or prohibited where necessary to protect the values for which the river area was designated” (Federal Register, Volume 47, Number 173, 1982, page 39459). The analysis of route designation within the corridor of eligible rivers is in chapter 3 of the final EIS, in the “Wilderness, Wild and Scenic Rivers, Inventoried Roadless Areas, and Special Management Areas” section. List all Outstanding Recreational Values (ORVs) for Wild and Scenic This information has been added to the final Wilderness, Wild and 2472 rivers and describe how the TMP will protect, and enhance them, and Scenic Rivers, Inventoried Roadless Areas, and Special Management otherwise generally comply with the requirements of the Wild and Areas report in the project record and summarized in the final EIS Scenic Rivers Act. under the corresponding section. The Forest Service failed to identify and specifically analyze sites As detailed in the final Wilderness, Wild and Scenic Rivers, Inventoried 2472 within IRAs that could be negatively impacted by motorized use Roadless Areas, and Special Management Area report, the effects including cross-country exemptions for dispersed motorized camping associated with the designation of motor vehicle use on the Tonto and motorized big game retrieval. National Forest in relationship to inventoried roadless areas has been analyzed. We are unsure what “sites” within the inventoried roadless areas that the commenter is referencing. However, as indicated in the draft record of decision, motorized access for dispersed camping will be provided via spur motorized trails. None of these trails are being designated within inventoried roadless areas. As for the use of a motor vehicles for the retrieval of big game, the draft record of decision allows for elk and bear, which will likely result in a maximum total of 209 trips across most of the Forest. It is impossible to determine where these retrievals will occur. Because of this and the number of

55 Travel Management on the Tonto National Forest

Comment Letter Original Comment Text Forest Service Response Number retrievals, the effects from such retrievals to inventoried roadless areas will be negligible. The OHV area located on the southwest portion of the forest overlays Bulldog Canyon Permit Zone does not allow cross-country travel. In 2472 Goldfield IRA, this area should be eliminated and cross-country travel permit zones, motorized vehicles have to stay on designated routes in the IRA should be prohibited and cannot travel cross-country. The Bulldog Canyon Permit Zone has been in existence long before (about 15 years) the Forest Service defined an OHV area as a discrete, specifically delineated space that is smaller, and in most cases much smaller, than a ranger district (36 CFR 212.1) that allows cross-country travel. Bulldog Canyon will remain and has been designated a permit zone in the draft record of decision. The proposed Desert Vista OHV area overlays the southern portion of Desert Vista is designated as a permit zone in the draft record of 2472 Lime Creek IRA, this area should be eliminated and cross-country decision, not an OHV area. The final EIS, in chapter 2, defines a travel in the IRA should be prohibited. permit zone. In permit zones, motorized vehicle users are required to obtain a permit to access the designated permit zone area which has locked gates and barriers restricting non-permitted motorized access. Cross-country travel is not allowed within permit zones and vehicles are restricted to designated routes. The designated Desert Vista Permit Zone does not overlay the southern portion of the Lime Creek Inventoried Roadless Area. The St. Claire Permit Zone does lay on the southern edge of the Lime Creek Inventoried Roadless Area. All unnecessary roads and trails within the Lime Creek Inventoried Roadless Area have been decommissioned. Additional recommendations for route closures or mitigation of impacts Based on our review of appendix H, we found the following: of the 80 2472 associated with OHVs located within Inventoried Roadless Areas are routes listed that are within the Tonto National Forest (2 routes listed found in Appendix H are within adjacent forests), there are 33 that are being designated for decommissioning, 18 that are system roads that are designated as roads, 4 are system roads that are being designated as administrative use only motorized trails, 25 that are system roads that are being designated as motorized trails. Of the 80 routes, 9 identified in the appendix are not within our inventoried roadless areas. All routes within the inventoried roadless area have been identified as necessary for proving access for recreation and other uses. Table 9 on page 36 of the Special Areas Report lists all Designated The referenced map was accidently omitted from the draft EIS. The 2472 Special Areas, Designated Research Natural Areas, and Proposed final EIS and the final Wilderness, Wild and Scenic Rivers, Inventoried Research Natural Areas. However, no maps are provided in the

56 Volume II–Response to Comments

Comment Letter Original Comment Text Forest Service Response Number Special Areas Report for any of the above classifications. No Roadless Areas, and Special Management Areas report in the project boundaries are shown on any of the four DEIS maps for any of these record contains the requested map. listed areas except for the Sierra Ancha Experimental Forest. It appears that the Roosevelt Lake Wildlife Area may be a Special Per the 1985 Tonto National Forest Plan the Roosevelt Lake Wildlife 2472 Area, however it is not listed on Table 9 on page 36 of the Special Area is not a special management area. Instead it is management Areas Report. Better maps and visual references for these areas area 6S and is managed for water-oriented development and would help those reviewing the Special Management Area dispersed recreation (page 179). As such it was analyzed as part of components of each alternative and any final plan determine the the general recreation effects section in chapter 3 of the final EIS. actual impact of proposed designations. Special management areas including designated wilderness, wild and scenic rivers, and inventoried roadless areas are analyzed in chapter 3 and have accompanying maps to illustrate where they are located within the Tonto National Forest. We are concerned that beyond a listing in table 9 on page 36 of the The analysis for the areas mentioned by the commenter are 2472 Special Area Report, we can find no text reference at all for the addressed in the final Wilderness, Wild and Scenic Rivers, Inventoried Proposed Sycamore Creek and Blue Point Cottonwood RNA. The Roadless Areas, and Special Management Area report in the project TNF needs to remedy this problem and explain how proposed RNAs record. would be impacted by this travel planning action. Further, designated and potential Wilderness and Wild and Scenic Comment is an opinion and lacks "supporting reasons for the 33 River areas, critical habitat for imperiled species, and riparian areas responsible official to consider" per 36 CFR 218.2. In chapter 3 of the must be made off limits to off-road vehicles and other motorized uses. final EIS, all of these resources are analyzed for the effects from motor These areas are essential for supporting biological diversity. vehicle use. I also ask that any eligible Wild and Scenic Rivers be protected from Comment is an opinion and lacks "supporting reasons for the 1101 off-road abuse. Although the amount of riparian vegetation on the responsible official to consider" per 36 CFR 218.2. In chapter 3 of the Tonto is limited, it is critical to the survival of many species and, final EIS, all of these resources are analyzed for the effects from motor because it is rare, should have even more protections. Please protect vehicle use. those areas from more off-road vehicle mayhem, as well. Thanks for the opportunity to comment on the proposals, and thank Comment lacks "supporting reasons for the responsible official to 1825 you to the NFS for trying to preserve the wilderness as much as consider" per 36 CFR 218.2. No further response warranted. possible without denying the public access. Motorized big game retrieval and motorized dispersed camping In chapter 2 of the final EIS, in the description for alternatives C and D, 2472 corridors cannot be permitted within designated Wilderness areas. As this restriction is clearly stipulated. the Forest Service notes, [b]y allowing the corridors for motorized big game retrieval and motorized dispersed camping, motorized users could unknowingly drive into a wilderness area DEIS at 130, Table 37.

57 Travel Management on the Tonto National Forest

Comment Letter Original Comment Text Forest Service Response Number There are several areas designated wilderness study areas. None of Comment is an opinion and lacks "supporting reasons for the 2482 these areas comply with the wilderness act. By the Wilderness Act of responsible official to consider" per 36 CFR 218.2. No further 1965, the area they encompass is supposed to be 5,000 acres and response warranted. without signs of man. There are stock tanks or old roads in all of them.

58 Volume II–Response to Comments

Visual Resources/Scenery Comment Letter Original Comment Text Forest Service Response Number You can see what has happened to the "natural landscape character" Comment is an opinion and lacks "supporting reasons for the 2520 without the barriers. If you don't put in the barriers, you might as well responsible official to consider" per 36 CFR 218.2. Visual resources on throw 8 years of work and this plan out the window. The OHV public the Forest, including natural landscape character, is one of many in general does not care about the "natural landscape character." The factors considered in the Travel Management final EIS. As indicated important thing is protecting the natural resource. The pipe/rail barrier in chapter 2, designated permit zones will likely require a barrier in is absolutely necessary from Hughes Corral northeast to Bushnell places where natural barriers do not exist to only allow admittance to Tank Trap on the Four Peaks Road (#143), and southeast from those with a permit. According to Forest Service, U.S. Department of Hughes Corral to Cottonwood Ranch. The unauthorized roads/trails in Agriculture, series of Agriculture Handbooks titled “National Forest these arears will encroach into the Four Peaks Wilderness area if they Landscape Management”, finishes of structures installed in the Forest, haven't already done so. Also, the boundary grazing fences between such as fencing, shall be low contrast to the characteristic landscape. the Cottonwood Unit grazing pastures and the Cottonwood Unit and Additional barriers that are required to address illegal use of motor Dos S Unit will be, and are, cut in several places by these vehicles and all activities associated with physically restricting use will unauthorized roads. These fences are essential to the Grazing be covered by additional environmental analysis in compliance with Management Plan for the Sunflower Allotment. In addition, target the National Environmental Policy Act. Various levels of motorized shooting in this area is out of control. The target areas are devoid of access are analyzed in the final Travel Management EIS. While we vegetation and littered with garbage and shell casings. The void of agree trash accumulation and fence cutting is an ongoing problem, the vegetation has increased erosion in these areas which will increase effects of non-motorized activities such as those associated with target the likelihood of the lead in the ground leaching down the drainages. shooting and grazing management are outside of the scope of The author of the Draft Travel Management Plan is concerned about designating motor vehicle use on the Tonto National Forest. Additional how the pipe/rail barriers will blend into the natural landscape. He/she information can also be found in the “Recreation,” “Visual Resources,” needs to visit this area to see the cut fences, the target shooting, and and “Law Enforcement” sections of the final EIS. the unauthorized roads/trails made by the OHVs and ask "How does this blend into the natural landscape?" The Forest Service should consider installing physical barriers As indicated in chapter 2 of the final EIS, designated permit zones will 2472 selectively to limit the worst resource damage, protect plants and likely require a barrier in places where natural barriers do not exist to animals, and limit the continued visual degradation of these areas. The only allow admittance to those with a permit. According to Forest barriers should be designed to blend with the landscape whenever Service, U.S. Department of Agriculture, series of Agriculture possible. Handbooks titled National Forest Landscape Management, finishes of structures installed in the Forest, such as fencing, shall be low contrast to the characteristic landscape. Additional barriers that are required to address illegal use of motor vehicles and all activities associated with physically restricting use will be covered by additional environmental analysis in compliance with the National Environmental Policy Act.

59 Travel Management on the Tonto National Forest

Comment Letter Original Comment Text Forest Service Response Number The Forest Service should also consider using natural vegetation, As indicated in chapter 2 of the final EIS, designated permit zones will 2472 such as cholla cacti, if it will decrease access, to protect these areas likely require a barrier in places where natural barriers do not exist to from more damage by OHV users. only allow admittance to those with a permit. According to Forest Service, U.S. Department of Agriculture, series of Agriculture Handbooks titled National Forest Landscape Management, finishes of structures installed in the Forest, such as fencing, shall be low contrast to the characteristic landscape. Additional barriers that are required to address illegal use of motor vehicles and all activities associated with physically restricting use will be covered by additional environmental analysis in compliance with the National Environmental Policy Act. Additional information can also be found in the “Recreation,” “Visual Resources,” and “Law Enforcement” sections of the final EIS.

60 Volume II–Response to Comments

Socioeconomics Comment Letter Original Comment Text Forest Service Response Number In compliance with the governmental ordinance known as Section 106, Comment is an opinion and lacks "supporting reasons for the 1281 the decommissioning of roads would reduce the adverse impact to responsible official to consider" per 36 CFR 218.2. However, archaeological resources within the TNF. Too many remote motorized access may have positive and negative effects to archaeological sites have been destroyed and compromised by archaeological sites. The relationship between site vandalism and unauthorized activities that access roads make possible. Remove the proximity to roads is discussed in detail in the Cultural Resources road, remove the vandalism. report in the project record, as summarized in chapter 3 of the final EIS. As a general guideline, routes that are within 200 meters of a Comment is an opinion and lacks "supporting reasons for the 2472 significant heritage, cultural, or archeological site should be closed. responsible official to consider" per 36 CFR 218.2. However, motorized access may have positive and negative effects to archaeological sites. The relationship between site vandalism and proximity to roads is discussed in detail in the Cultural Resources report in the project record, as summarized in chapter 3 of the final EIS.

61 Travel Management on the Tonto National Forest

Cultural Resources Comment Letter Original Comment Text Forest Service Response Number In compliance with the governmental ordinance known as Section 106, Comment is an opinion and lacks "supporting reasons for the 1281 the decommissioning of roads would reduce the adverse impact to responsible official to consider" per 36 CFR 218.2. However, archaeological resources within the TNF. Too many remote motorized access may have positive and negative effects to archaeological sites have been destroyed and compromised by archaeological sites. The relationship between site vandalism and unauthorized activities that access roads make possible. Remove the proximity to roads is discussed in detail in the Cultural Resources road, remove the vandalism. report in the project record, as summarized in chapter 3 of the final EIS. As a general guideline, routes that are within 200 meters of a Comment is an opinion and lacks "supporting reasons for the 2472 significant heritage, cultural, or archeological site should be closed. responsible official to consider" per 36 CFR 218.2. However, motorized access may have positive and negative effects to archaeological sites. The relationship between site vandalism and proximity to roads is discussed in detail in the Cultural Resources report in the project record, as summarized in chapter 3 of the final EIS.

62 Volume II–Response to Comments

Game and Nongame Species Comment Letter Original Comment Text Forest Service Response Number Motorized Big Game Retrieval CMBGR) As an ID Team member, the Although 36 CFR 212.51(b) and FSM 7715.74 do not identify specific 2497 Department provided an in-depth analysis of MBGR on the Forest that "big game animals" for motorized big game retrieval, this regulation assisted other resource specialists in their analysis of this activity on and Forest Service manual direction states that the Forest Service natural and cultural resources. This analysis should assist in making should use this authority sparingly as to not undermine the purposes your decision on MBGR and its effects on the Forest. The total number of the travel management rule and to promote consistency in its of motorized big game retrievals on the Forest, including deer, is implementation. As described in the final EIS, under alternative C, estimated to be less than 550 trips per year. MBGR is restricted to one fuelwood gathering trips are limited to specific times of the year, trip in and out for retrieval of a large game animal. Fuelwood gathering specific areas, and up to 300 feet from a designated route. permits allow unlimited trips to retrieve wood up to 300 feet from a Additionally, in practice, these areas are not all open for use every designated route. At the very least, it is essential that MBGR is dealt year. It is dependent on existing vegetation conditions and the need to with in the same fashion as other forest uses such as fuelwood decrease dead and down material. Additional stipulations for fuelwood gathering. However, as the analysis in the DEIS indicates that there gathering are attached to fuelwood gathering permits such as the are no anticipated adverse effects to natural or cultural resources as a requirement to not cause resource damage. Motorized big game result of MBGR trips there is no reason to limit them. Therefore, the retrieval will be authorized for elk and bear up to 1 mile from Department requests the addition of deer for motorized retrieval be designated routes under the same alternative. The motorized big included in the proposed alternative. game retrieval for deer in alternative C would result in an estimated 341 additional trips based on the Arizona Game and Fish Department specialist report. The inclusion of deer was analyzed in alternative D. Motorized big game retrieval and other Forest uses (such as fuelwood gathering) were analyzed separately because of differing effects to natural and cultural resources specific to that use. Authorize motorized big game retrieval for all species of game meeting Although 36 CFR 212.51(b) and FSM 7715.74 do not identify specific 2512 the definition of 'big game' in the Arizona Game and Fish Department "big game animals" for motorized big game retrieval, this regulation hunting regulations, or alternatively for all'big game' animals requiring and Forest Service manual direction states that the Forest Service a hunting tag, with the exception of turkeys. The authorized motorized should use this authority sparingly as to not undermine the purposes big game retrieval consists of one trip each way from the downed of the travel management rule and to promote consistency in its animal to the closest legally open road or trail, regardless of distance, implementation. The final EIS analyzed the effects of motorized big by the most direct route compatible with safety and the preservation of game retrieval for deer, elk, and bear on natural and cultural other values such as riparian areas, archeological sites, etc. resources. Other species of big game were not analyzed due to input from the Arizona Game and Fish Department indicating that those species were of small enough size to not require motorized big game retrieval, occurred in habitat that naturally precludes motorized big game retrieval, or quantity of harvest did not rise to a level to warrant a definitive need for motorized big game retrieval.

63 Travel Management on the Tonto National Forest

Comment Letter Original Comment Text Forest Service Response Number The travel management plan DEIS limits the species of big game Although 36 CFR 212.51(b) and FSM 7715.74 do not identify specific 2512 allowed for motorized big game retrieval to elk, bear and deer only "big game animals" for motorized big game retrieval, this regulation {Alternative D), or even elk and bear only (Alternative C). Gila and Forest Service manual direction states that the Forest Service County believes that the limitation of motorized big game retrieval to should use this authority sparingly as to not undermine the purposes only a few species is arbitrary and does not meet the intent of the of the travel management rule and to promote consistency in its motorized big game retrieval exemption mechanism. Specifically, other implementation. The final EIS analyzed the effects of motorized big big game species such as, but not limited to, sheep, antelopes, game retrieval for deer, elk, and bear on natural and cultural mountain lions, javelina, etc. may in the present and/or in the future be resources. Other species of big game were not analyzed due to input hunted within the confine of the Arizona national forests and should from the Arizona Game and Fish Department indicating that those qualify for motorized big game retrieval. species were of small enough size to not require motorized big game retrieval, occurred in habitat that naturally precludes motorized big game retrieval, or quantity of harvest did not rise to a level to warrant a definitive need for motorized big game retrieval. The TNF should not designate MBGR areas. Comment is an opinion and lacks "supporting reasons for the 2471 responsible official to consider" per 36 CFR 218.2. Per the final Travel Management Rule, "In designating routes, 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 or retrieval of a downed big game animal by an individual who has legally taken that animal" (36 CFR 212.51(b)). This is also in compliance with Forest Service Manual 7715.74 which allows the responsible official to include the limited use of motor vehicles within a specified distance of certain Forest roads and Forest trails where motor vehicle use is allowed, 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. Additionally, the exclusion of motorized big game retrieval was analyzed under alternative B in the final EIS. The TNF should also analyze alternatives that limit MBGR corridors Per the final Travel Management Rule, "In designating routes, the 2471 much more than those alternatives analyzed in the DEIS. 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 or retrieval of a downed big game animal by an individual who has legally taken that animal" (36 CFR 212.51(b)). This is also in compliance with Forest Service Manual 7715.74 which

64 Volume II–Response to Comments

Comment Letter Original Comment Text Forest Service Response Number allows the responsible official to include the limited use of motor vehicles within a specified distance of certain Forest roads and Forest trails where motor vehicle use is allowed, 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. Alternatives B, C, and D analyze varying degrees of motor vehicle use for the purposes of big game retrieval. Alternative D would allow the most area for the most species, alternative C would authorize a reduced area for elk and bear only, and alternative B would exclude motorized big game retrieval entirely. This analysis can be found in the final EIS. We feel that this range and the effects associated with it allow the Forest Supervisor enough variability to make a supportable decision. Also, the commenter did not offer an additional distance or location for consideration. Gila County therefore requests that an analysis of land coverage The Tonto National Forest is 2,964,308 acres in size. Excluding all 2512 resulting from the combined values of corridor width AND road designated wilderness areas (totaling 615,855) where motor vehicle network density be performed, and that if necessary districts featuring use is strictly prohibited, that would leave 79% of the Forest that could a lower density of roads be managed with either no corridor, or wider potentially be accessed with a motor vehicle for big game retrieval. corridors as required in order to allow motorized big game retrieval to Furthermore, the final Travel Management Rule states that "within a happen on at least 95% of the hunting areas in each districts. specified distance of certain designated routes, and if appropriate within specified time periods, solely for the purposes of dispersed camping or retrieval of a downed big game animal by an individual who has legally taken that animal" (36 CFR 212.51(b)). This is also in compliance with Forest Service Manual 7715.74 which allows the responsible official to include the limited use of motor vehicles within a specified distance of certain Forest roads and Forest trails where motor vehicle use is allowed, 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." The Arizona Game and Fish Department specialist report, the final Game and Non-Game report in the project record and summarized in the final EIS, describes the available Tonto National Forest lands available to motorized big game retrieval and analyzed under each alternative. Additionally, the effects of route density and motorized big game retrieval were analyzed throughout chapter 3 of the final EIS.

65 Travel Management on the Tonto National Forest

Comment Letter Original Comment Text Forest Service Response Number And off-road vehicles should be prohibited from going through miles of Comment is an opinion and lacks "supporting reasons for the 33 the forest to pick up hunted game - even most hunters agree that responsible official to consider" per 36 CFR 218.2. Per the final Travel motorized vehicles only drive away animals and disturb other users. Management Rule, "In designating routes, the responsible official may include in the designation the limited use of motor vehicles within a one mile of designated routes, and if appropriate within specified time periods, solely for the purposes of dispersed camping or retrieval of a downed big game animal by an individual who has legally taken that animal" (36 CFR 212.51(b)). This is also in compliance with Forest Service Manual 7715.74 which allows the responsible official to include the limited use of motor vehicles within a specified distance of certain Forest roads and Forest trails where motor vehicle use is allowed, 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. Alternatives B, C, and D analyze varying degrees of motor vehicle use for the purposes of big game retrieval. Alternative D would allow the most area for the most species, alternative C would authorize a reduced area for elk and bear only, and alternative B would exclude motorized big game retrieval entirely. This is described in chapter 2 of the final EIS. Conflict among motorized and non-motorized user groups was also analyzed in the “Recreation” section of the final EIS. Restrict OHVs for hunting--including scouting and picking up downed Per the final Travel Management Rule, "In designating routes, the 504 game. I hunted for years and through all that time have walked my responsible official may include in the designation the limited use of game out. Horses are another alternative that could offer local people motor vehicles within a one mile of designated routes, and if an income if they rent their horses as packhorses. Non-motorized appropriate within specified time periods, solely for the purposes of alternatives are good for people and the land. dispersed camping or retrieval of a downed big game animal by an individual who has legally taken that animal" (36 CFR 212.51(b)). This is also in compliance with Forest Service Manual 7715.74 which allows the responsible official to include the limited use of motor vehicles within a specified distance of certain Forest roads and Forest trails where motor vehicle use is allowed, 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. Alternatives B, C, and D analyze varying degrees of motor vehicle use for the purposes of big game retrieval. Alternative D would allow the most area for the most species, alternative C would authorize a reduced area for elk and bear only, and alternative B would exclude

66 Volume II–Response to Comments

Comment Letter Original Comment Text Forest Service Response Number motorized big game retrieval entirely. This is described in chapter 2 of the final EIS. Conflict among motorized and non-motorized user groups was also analyzed in the “Recreation” section of the final EIS. Non-motorized hunting opportunities occur in many locations on the Forest. However, this travel management decision only applies to motorized access of the Forest. Non-motorized activities are outside of the scope of this analysis. Please limit driving for picking up hunted game as well -- more Per the final Travel Management Rule, "In designating routes, the 1101 vehicles driving cross-country in the forest is bad for wildlife and responsible official may include in the designation the limited use of wildlife habitat and tends to drive the animals away as well as disturb motor vehicles within a one mile of designated routes, and if other forest users, including other hunters. appropriate within specified time periods, solely for the purposes of dispersed camping or retrieval of a downed big game animal by an individual who has legally taken that animal" (36 CFR 212.51(b)). This is also in compliance with Forest Service Manual 7715.74 which allows the responsible official to include the limited use of motor vehicles within a specified distance of certain Forest roads and Forest trails where motor vehicle use is allowed, 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. Alternatives B, C, and D analyze varying degrees of motor vehicle use for the purposes of big game retrieval. Alternative D would allow the most area for the most species, alternative C would authorize a reduced area for elk and bear only, and alternative B would exclude motorized big game retrieval entirely. This is described in chapter 2 of the final EIS. The effects of motorized big game retrieval is analyzed in the “Wildlife and Plant Habitat Resources” section of the final EIS. Conflict among motorized and non-motorized user groups was also analyzed in the “Recreation” section of the final EIS. Non-motorized hunting opportunities occur in many locations on the Forest. However, this travel management decision only applies to motorized access of the Forest. The AES does not understand what this issue is and why the motor The National Environmental Policy Act requires Federal agencies to 2405 vehicle use of big game retrieval for elk, bear, mule deer, and whitetail develop alternatives in an EIS that are distinctly different from each deer is not allowed for all alternatives. At most under, Alternative D other and to subsequently analyze the potential effects under each there would only be 550 short, one time retrievals (DEIS pg. 52) over a alternative (36 CFR 1501.7(a)). Since motorized big game retrieval total area that is over 2 million acres in size (DEIS pg. 63). Most was identified as a significant issue during scoping, each alternative

67 Travel Management on the Tonto National Forest

Comment Letter Original Comment Text Forest Service Response Number retrievals would use ATVs equipped with low pressure tires that are has different levels of motorized big game retrieval to help the decision known to have less soil compaction and cause less ruts even under maker and public understand the trade-offs for each. The responsible wet conditions. Under Alternative D (where deer is included) the official has the authority to include elements of other alternatives, with effects of big game retrieval is not likely to be adverse for cultural the selected alternative, as long as those elements were analyzed in resources (DEIS pg. 200). Based on the low number of trips required, the EIS. Although 36 CFR 212.51(b) and FSM 7715.74 do not identify short distance needed for retrieval, and low number of OHV crossings specific "big game animals" for motorized big game retrieval, this of a site, motorized big game retrieval will have minimal effects on soil regulation and Forest Service manual direction states that the Forest condition (DEIS pg. 479 and 482). Negligible impacts to watershed Service should use this authority sparingly as to not undermine the conditions would be expected due to the small number of motorized purposes of the Travel Management Rule and to promote consistency retrievals and the large area available for these retrievals (DEIS pg. in its implementation. The final EIS analyzed the effects of motorized 470). If the effects of allowing game retrieval for elk, bear, mule deer, big game retrieval for deer, elk, and bear on natural and cultural and whitetail deer is not likely to be adverse or has negligible impacts resources. Other species of big game were not analyzed due to input why is it not being allowed? Enforcement would be difficult if not from the Arizona Game and Fish Department indicating that those impossible, resource damage is minimal, and to not allow it only species were of small enough size to not require motorized big game penalizes the Forest's user. retrieval, occurred in habitat that naturally precludes motorized big game retrieval, or quantity of harvest did not rise to a level to warrant a definitive need for motorized big game retrieval. Conflict among motorized and non-motorized user groups was also analyzed in the “Recreation” section of the final EIS. SCI supports an alternative that would encourage rather than Comment lacks detail and "supporting reasons for the responsible 2502 discourage hunters to utilize Tonto National Forest and that would official to consider" per 36 CFR 218.2. However, alternatives B, C, provide realistic access and retrieval opportunities for hunters of all and D analyze varying degrees of motor vehicle use for the purposes levels and physical abilities. of big game retrieval. Alternative D would allow the most area for the most species, Alternative C would authorize a reduced area for elk and bear only, and alternative B would exclude motorized big game retrieval entirely. This is described in chapter 2 of the final EIS. In addition, The CHAMP permit (for hunters with disabilities) allows qualifying persons with the permit to use their motor vehicle off designated roads to wait for big game and to retrieve big game as long as it is not in conflict with other laws is currently honored on Tonto National Forest. "Stop Cross country motorized travel" (preventing OHV use anywhere Comment is an opinion and lacks "supporting reasons for the 1983 they want to travel on the forest with the exception of hunters to responsible official to consider" per 36 CFR 218.2 However, after a retrieve game). system of motorized routes and areas is designated Motor vehicle use off designated roads and trails and outside designated areas is prohibited by 36 CFR 261.13 Furthermore, alternatives B, C, and D

68 Volume II–Response to Comments

Comment Letter Original Comment Text Forest Service Response Number analyze varying degrees of motor vehicle use for the purposes of big game retrieval. Alternative D would allow the most area for the most species, alternative C would authorize a reduced area for elk and bear only, and alternative B would exclude motorized big game retrieval entirely. This is described in chapter 2 of the final EIS. . Per the final Travel Management Rule, "In designating routes, the responsible official may include in the designation the limited use of motor vehicles within a one mile of designated routes, and if appropriate within specified time periods, solely for the purposes of dispersed camping or retrieval of a downed big game animal by an individual who has legally taken that animal" (36 CFR 212.51(b)). This is also in compliance with Forest Service Manual 7715.74 which allows the responsible official to include the limited use of motor vehicles within a specified distance of certain Forest roads and forest trails where motor vehicle use is allowed, 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. "Stop Cross country motorized travel" (preventing OHV use anywhere Comment is an opinion and lacks "supporting reasons for the 2500 they want to travel on the forest with the exception of hunters to responsible official to consider" per 36 CFR 218.2 However, after a retrieve game). system of motorized routes and areas is designated motor vehicle use off designated roads and trails and outside designated areas is prohibited by 36 CFR 261.13. Furthermore, alternatives B, C, and D analyze varying degrees of motor vehicle use for the purposes of big game retrieval. Alternative D would allow the most area for the most species, alternative C would authorize a reduced area for elk and bear only, and alternative B would exclude motorized big game retrieval entirely. This is described in chapter 2 of the final EIS. Per the final Travel Management Rule, "In designating routes, the responsible official may include in the designation the limited use of motor vehicles within a one mile of designated routes, and if appropriate within specified time periods, solely for the purposes of dispersed camping or retrieval of a downed big game animal by an individual who has legally taken that animal" (36 CFR 212.51(b)). This is also in compliance with Forest Service Manual 7715.74 which allows the responsible official to include the limited use of motor vehicles within a specified distance of certain Forest roads and Forest trails where motor vehicle use is allowed, and if appropriate within specified time periods, solely for the

69 Travel Management on the Tonto National Forest

Comment Letter Original Comment Text Forest Service Response Number purposes of retrieval of a downed big game animal by an individual who has legally taken that animal. Stop cross country motorized travel with the exception of hunters Comment is an opinion and lacks "supporting reasons for the 2519 retrieving game. responsible official to consider" per 36 CFR 218.2 However, after a system of motorized routes and areas is designated Motor vehicle use off designated roads and trails and outside designated areas is prohibited by 36 CFR 261.13. Furthermore, alternatives B, C, and D analyze varying degrees of motor vehicle use for the purposes of big game retrieval. Alternative D would allow the most area for the most species, alternative C would authorize a reduced area for elk and bear only, and alternative B would exclude motorized big game retrieval entirely. This is described in chapter 2 of the final EIS. Per the final Travel Management Rule, "In designating routes, the responsible official may include in the designation the limited use of motor vehicles within a one mile of designated routes, and if appropriate within specified time periods, solely for the purposes of dispersed camping or retrieval of a downed big game animal by an individual who has legally taken that animal" (36 CFR 212.51(b)). This is also in compliance with Forest Service Manual 7715.74 which allows the responsible official to include the limited use of motor vehicles within a specified distance of certain Forest roads and Forest trails where motor vehicle use is allowed, 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. The need for motorized game retrieval in the Tonto National Forest The need for the use of a motor vehicle in the retrieval of big game 2521 has been unsubstantiated and therefore should be eliminated from the was brought up by many commenters to the proposed action. As such, preferred alternative. In particular, except by CHAMP permit, we it is one of the identified issues as detailed in chapter 1 of the final EIS. strongly oppose the provision which allows animals to be retrieved In chapter 3 of the final EIS, hunter satisfaction was one of the with motorized vehicles up to one mile from the trail. While we analysis factors for the “Game and Nongame” section, where motor understand the Arizona Game and Fish has supported this provision, vehicle use was a part of this analysis. as hunters who are willing to walk and work for our big game, we take exception to the notion that hunters need motorized equipment to retrieve game. We simply do not need an exception to a rule that is aimed at protecting the habitat that our wildlife, and ultimately we hunters depend on.

70 Volume II–Response to Comments

Law Enforcement Comment Letter Original Comment Text Forest Service Response Number Motorized off-road travel, whether for activities such as big game We applied the minimization criteria identified in 36 CFR 212.55(b) to 2503 retrieval, dispersed camping, fuelwood gathering, or within minimize damage to soil, watershed, vegetation, other Forest concentrated off-highway vehicle areas, when combined, can impact resources, and disruption of wildlife habitats. The Mexican spotted owl listed species. Although each of these activities is evaluated was analyzed under all alternatives in the final EIS and in the separately in the effects evaluation for listed species, the discussion biological assessment for affects to the species Forestwide. This lacks the big picture perspective of how these activities combined may analysis can also be found in the final Wildlife and Plant Habitat affect a listed species that occurs across several Ranger Districts. For Resources report in the project record. Overall, the designations in the example, critical habitat for the Mexican spotted owl may be potentially draft record of decision will benefit the Mexican spotted owl by impacted by cross-country travel in all six Ranger Districts as a result eliminating cross-country travel on the Payson and Pleasant Valley of the implementation of Alternative C. We recommend the document ranger districts which encompasses 79% of the Mexican spotted owl be augmented with an analysis of the synergistic effects of these critical habitat on the Forest. This would substantially reduce the activities. number of miles of open roads and motorized trails and disturbance from cross-country travel within Mexican spotted owl protected activity centers, cores, and critical habitat; and eliminating year-round disturbance protected activity centers and cores during nesting and early fledging periods on the Payson and Pleasant Valley ranger districts. The Forest Service is required, as a Federal agency, to consult with U.S. Fish and Wildlife Service and to comply with the Endangered Species Act and promote recovery of a listed species. The biological opinion from U.S. Fish and Wildlife Service concurs with the analysis found in the final EIS and its findings for listed species. Alternative C, Motor Vehicle Use for Big Game Retrieval 1 Under We applied the minimization criteria identified in 36 CFR 212.55(b) to 2489 Alternative C, Big Game Retrieval, the DEIS states that approximately minimize damage to soil, watershed, vegetation, other Forest 15.22 acres of flycatcher critical habitat would be impacted. This resources, and disruption of wildlife habitats. Motorized big game acreage needs to be reevaluated because over 28.15 acres 22 of retrieval would only impact approximately 15 acres of flycatcher critical critical habitat are being impacted by roads alone, and this action habitat as designated in the draft record of decision. This is a great extends a mile beyond those same roads. reduction from the current condition. The final Wildlife and Plant Habitat Resources report in the project record, as summarized in the final EIS, analyzes the species specific effects from designating a system for motor vehicle use on the Tonto National Forest. Under Alternatives C and 06 Figure 10 (Map of OHV Areas for The Travel management Rule “provides for a system of National 2489 Alternative C)7 and the associated text indicates that unrestricted Forest System roads, National Forest System trails, and areas on motorized cross-country travel would be permitted around the entire National Forest System lands that are designated for motor vehicle perimeters of both Bartlett and Roosevelt lakes between the variable use. After these roads, trails, and areas are designated, motor vehicle

71 Travel Management on the Tonto National Forest

Comment Letter Original Comment Text Forest Service Response Number water level and the high watermark. 8 The proposed action at use, including the class of vehicle and time of year, not in accordance Roosevelt lake would potentially allow motorized vehicle users access with these designations is prohibited by 36 CFR 261.13. Motor vehicle to areas that are currently occupied by flycatchers, cuckoos, nesting use off designated roads and trails and outside designated areas is bald eagles, northern Mexican gartersnakes, as well as areas prohibited by 36 CFR 261.13” (36 CFR 212.50(a)). The draft record of previously occupied by flycatchers that are re-vegetating. The decision does not designate cross-country travel, nor does it preclude proposed action may also provide access to the Willow Flycatcher the use of necessary closure orders. The proposed OHV areas that Motorized Closure area and, potentially, to bald eagle closure areas. the commenter refers to were reexamined with a focus on the However, the DEIS states that: 5 Pages 36-37 DEIS. 6 Page 48 DEIS. minimization criteria detailed in the final Travel Management Rule (36 Motorized cross-country travel would be limited to the same areas that CFR 212.55). For the OHV area associated with Bartlett Lake, it are being proposed in Alternative C. 7 Page 38 DEIS. Figure 10 Map changed from 922 acres to an approximate total of 177 acres, a 421% of OHV Areas for Alternatives C. 8 Pages 36-38 DEIS. "The effect of decrease. And for Roosevelt Lake, which is home to several the cross-country travel will not be analyzed further as routes created threatened and endangered species, including southwestern willow by cross-country travel are not considered U.S. Forest Service routes." flycatcher, the designated OHV area changed from 4,508 acres to an 9 Cross-country travel that results from the proposed actions and approximate total of 554 acres, a 713% decrease. The Forest Service policies set forth in the DEIS are, at the very least, an indirect action is required, as a Federal agency, to consult with U.S. Fish and Wildlife that needs to be analyzed. The potential impacts to federally listed and Service and to comply with the Endangered Species Act and promote protected species and their habitats should not be ignored in the recovery of a listed species. A revised alternative C, as described in document. the final EIS, was analyzed under a biological assessment and consulted on with U.S. Fish and Wildlife Service for all listed species. This analysis included the effects of designating referenced OHV areas. The biological opinion from U.S. Fish and Wildlife Service concurs with the analysis found in the final EIS and its findings for listed species. TNF must fully analyze the proposed unrestricted motorized cross- The Travel management Rule “provides for a system of National 2489 country travel around the entire perimeters of Bartlett and Roosevelt Forest System roads, National Forest System trails, and areas on lakes "between the variable water level and the high water mark.' National Forest System lands that are designated for motor vehicle use. After these roads, trails, and areas are designated, motor vehicle use, including the class of vehicle and time of year, not in accordance with these designations is prohibited by 36 CFR 261.13. Motor vehicle use off designated roads and trails and outside designated areas is prohibited by 36 CFR 261.13” (36 CFR 212.50(a)). The draft record of decision does not designate cross-country travel, nor does it preclude the use of necessary closure orders. The proposed OHV areas that the commenter refers to were reexamined with a focus on the minimization criteria detailed in the final Travel Management Rule (36 CFR 212.55). For the OHV area associated with Bartlett Lake, it changed from 922 acres to an approximate total of 177 acres, a 421%

72 Volume II–Response to Comments

Comment Letter Original Comment Text Forest Service Response Number decrease. And for Roosevelt Lake, which is home to several threatened and endangered species, including southwestern willow flycatcher, the designated OHV area changed from 4,508 acres to an approximate total of 554 acres, a 713% decrease. The Forest Service is required, as a Federal agency, to consult with U.S. Fish and Wildlife Service and to comply with the Endangered Species Act and promote recovery of a listed species. A revised alternative C, as described in the final EIS, was analyzed under a biological assessment and consulted on with U.S. Fish and Wildlife Service for all listed species. This analysis included the effects of designating referenced OHV areas. The biological opinion from U.S. Fish and Wildlife Service concurs with the analysis found in the final EIS and its findings for listed species. The TNF should retain existing ROS classifications. XIX. Wildlife and The first comment is an opinion and lacks "supporting reasons for the 2471 Plant Impacts The TNF has determined that the effects to responsible official to consider" per 36 CFR 218.2. Analysis of the southwestern willow flycatcher and Mexican spotted owl under effects of designating a motorized system to listed species, including Alternative C and D are may affect the species and is likely to the referenced species, for each alternative can be found in the final adversely affect the species or its habitat. DEIS at 67. Both Wildlife and Plant Habitat Resources report in the project record, as alternatives are also likely to result in destruction or adverse summarized in the final EIS and is also in the biological assessment. modification of designated critical habitat for both species. Id. The designations of the draft record of decision are expected to Additionally, Alternatives C and D are likely to adversely affect the benefit the species overall by reducing the miles of routes in Arizona hedgehog cactus. designated critical habitat, thereby reducing direct effects to the species, as well as reducing habitat degradation. The draft record of decision is based on the analysis found in the biological assessment and under the modified alternative C in the final EIS. The biological opinion from U.S. Fish and Wildlife Service concurs with the analysis found in the final EIS and its findings for listed species. The Forest Service's proposed plan would harm wildlife populations We applied the minimization criteria identified in 36 CFR 212.55(b) to 33 such as Mexican spotted owls and their habitat. This is unacceptable. minimize damage to soil, watershed, vegetation, other Forest Managing motorized use to assist in the recovery of listed species resources, and disruption of wildlife habitats. The Mexican spotted owl should be a priority for the final travel-planning rule. was analyzed under all alternatives and the biological assessment for affects to the species. Overall, the designations in the draft record of decision will benefit the Mexican spotted owl by eliminating cross- country travel on the Payson and Pleasant Valley ranger districts which encompasses 79% of the Mexican spotted owl critical habitat on the Forest. This substantially reduced the number of miles of open

73 Travel Management on the Tonto National Forest

Comment Letter Original Comment Text Forest Service Response Number roads and motorized trails and disturbance from cross-country travel within Mexican spotted owl protected activity centers, cores, and critical habitat; and eliminating year-round disturbance protected activity centers and cores during nesting and early fledging periods on the Payson and Pleasant Valley ranger districts. The Forest Service is required, as a Federal agency, to consult with U.S. Fish and Wildlife Service and to comply with the Endangered Species Act and promote recovery of a listed species. The biological opinion from U.S. Fish and Wildlife Service concurs with the analysis found in the final EIS and its findings for listed species. The Forest Service's current proposal would harm wildlife populations, We applied the minimization criteria identified in 36 CFR 212.55(b) to 1101 such as Mexican spotted owls, and their habitat. This is unacceptable. minimize damage to soil, watershed, vegetation, other Forest The plan should help to recover any listed species, not further imperil resources, and disruption of wildlife habitats. The Mexican spotted owl them. was analyzed under all alternatives and the biological assessment for affects to the species. Overall, the designations in the draft record of decision will benefit the Mexican spotted owl by eliminating cross- country travel on the Payson and Pleasant Valley ranger districts which encompasses 79% of the Mexican spotted owl critical habitat on the Forest; Substantially reducing the number of miles of open roads and motorized trails and disturbance from cross-country travel within Mexican spotted owl protected activity centers, cores, and critical habitat; and eliminating year round disturbance to protected activity centers and cores during nesting and early fledging periods on the Payson and Pleasant Valley ranger districts. The Forest Service is required, as a Federal agency, to consult with U.S. Fish and Wildlife Service and to comply with the Endangered Species Act and promote recovery of a listed species. The biological opinion from U.S. Fish and Wildlife Service concurs with the analysis found in the final EIS and its findings for listed species. There are a plethora of 'Open, Unknown Maintenance Level' roads, The minimization criteria identified in 36 CFR 212.55(b) was applied in especially below the Mogollon Rim. These roads are detrimental to the identifying alternatives to minimize damage to soil, watershed, environment, leading to erosion, and degeneration of bird and wildlife vegetation, other Forest resources, and disruption of wildlife habitats. habitat. The motorized system designated in the draft record of decision reduces the miles of roads from the current condition which will have overall beneficial effects for wildlife species, by reducing human disturbance and habitat degradation. The chapter 3 of the final EIS

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Comment Letter Original Comment Text Forest Service Response Number analyzes the effects of this designation on Forest resources including soils and wildlife habitat. The TNF acknowledges that the forest plays a vital role in Arizona by The travel management planning effort is meant to increase the 2471 supporting crucial wildlife habitat and maintaining Arizonas wildlife effectiveness of managing motorized uses to reduce Forest impacts heritage as well as providing significant opportunities for wildlife while still allowing multiple uses across the Forest. The designation of related recreation and associated economic effects. DEIS at 245. a system for motorized use has been implemented in other national However, the Forest Service’s preferred alternative for this action has forests throughout the Nation and has been studied showing an a high likelihood of directly resulting in loss of individuals and habitat improvement in public lands management (Divine and Foti 2004). The for listed species. This is unacceptable as a management strategy and minimization criteria identified in 36 CFR 212.55(b) was applied in creates the potential for violations of the Forest Service’s legal duties identifying alternatives to minimize damage to soil, watershed, to protect species, assist in species recovery, and provide sustainable vegetation, other Forest resources, and disruption of wildlife habitats. management for the National Forest System. Analysis for listed, management indicator species, sensitive species and migratory birds for all alternatives, including the revised alternative C can be found in the chapter 3 of the final EIS. The “Game and Nongame Species” (wildlife related to recreation) section also analyzes potential effects to wildlife related recreation. The Forest Service is required, as a Federal agency, to consult with U.S. Fish and Wildlife Service and to comply with the Endangered Species Act and promote recovery of a listed species. The biological opinion from U.S. Fish and Wildlife Service concurs with the analysis found in the final EIS and its findings for listed species. No unauthorized routes should be designated for use within MSO Comment is an opinion and lacks "supporting reasons for the 2472 critical habitat “there are numerous other areas for motorized users to responsible official to consider" per 36 CFR 218.2. The draft record of recreate, and MSO habitat constitutes a small percentage of the TNF. decision does not designate any unauthorized routes within Mexican Additionally, much of this critical habitat is in relatively steep areas, spotted owl habitat. We applied the minimization criteria identified in where erosion of roads and trails is more severe. 36 CFR 212.55(b) to minimize damage to soil, watershed, vegetation, other Forest resources, and disruption of wildlife habitats. The Mexican spotted owl was analyzed under all alternatives and the biological assessment for effects to the species. Overall, the designations in the draft record of decision will benefit the Mexican spotted owl by eliminating cross-country travel on the Payson and Pleasant Valley ranger districts which encompasses 79% of the Mexican spotted owl critical habitat on the Forest; Substantially reducing the number of miles of open roads and motorized trails and disturbance from cross-country travel within Mexican spotted owl protected activity centers, cores, and critical habitat; and eliminating

75 Travel Management on the Tonto National Forest

Comment Letter Original Comment Text Forest Service Response Number year-round disturbance to protected activity centers and cores during nesting and early fledging periods on the Payson and Pleasant Valley ranger districts. The Forest Service is required, as a Federal agency, to consult with U.S. Fish and Wildlife Service and to comply with the Endangered Species Act and promote recovery of a listed species. The biological opinion from U.S. Fish and Wildlife Service concurs with the analysis found in the final EIS and its findings for listed species. ML1 roads, regardless of current use, should be decommissioned if Comment is an opinion and lacks "supporting reasons for the 2472 located within MSO critical habitat. Many of the roads slated for responsible official to consider" per 36 CFR 218.2. The Travel administrative use under the preferred alternative would be management Rule “provides for a system of National Forest System decommissioned under other alternatives. If these roads are not roads, National Forest System trails, and areas on National Forest absolutely necessary for Forest Service purposes, they should be System lands that are designated for motor vehicle use. After these decommissioned. The Forest Service knows that administrative roads roads, trails, and areas are designated, motor vehicle use, including will remain in use by the public and should plan accordingly. the class of vehicle and time of year, not in accordance with these designations is prohibited by 36 CFR 261.13. Motor vehicle use off designated roads and trails and outside designated areas is prohibited by 36 CFR 261.13” (36 CFR 212.50(a)). The draft record of decision does not designate any unauthorized routes within Mexican spotted owl habitat. We applied the minimization criteria identified in 36 CFR 212.55(b) to minimize damage to soil, watershed, vegetation, other Forest resources, and disruption of wildlife habitats. The Mexican spotted owl was analyzed under all alternatives and the biological assessment for effects to the species. Overall, the designations in the draft record of decision will benefit the Mexican spotted owl by eliminating cross-country travel on the Payson and Pleasant Valley ranger districts which encompasses 79% of the Mexican spotted owl critical habitat on the Forest substantially reducing the number of miles of open roads and motorized trails and disturbance from cross-country travel within Mexican spotted owl protected activity centers, cores, and critical habitat; and eliminating year round disturbance to protected activity centers and cores during nesting and early fledging periods on the Payson and Pleasant Valley ranger districts. The Forest Service is required, as a Federal agency, to consult with U.S. Fish and Wildlife Service and to comply with the Endangered Species Act and promote recovery of a listed species. The biological opinion from U.S. Fish and Wildlife Service concurs with the analysis found in the final EIS and its findings for listed species. Alternatives B, C and D all reduce the miles

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Comment Letter Original Comment Text Forest Service Response Number of roads in designated critical habitat. A revised alternative C, as described in the final EIS, was analyzed under a biological assessment and consulted on with U.S. Fish and Wildlife Service for Mexican spotted owl and other listed species. Under alternative C a determination of may effect not likely to adversely affect has been determined and concurred by U.S. Fish and Wildlife Service. ML2-ML5 roads in MSO habitat should likewise be decommissioned Comment is an opinion and lacks "supporting reasons for the 2472 unless they are providing the only access to designated non-motorized responsible official to consider" per 36 CFR 218.2. As a multiple use trailheads, wilderness areas, etc. or provide the only means of safe agency, it is the intent of the Tonto National Forest to provide for all travel through forest areas. As stated above, for those wishing to kinds of recreation opportunities while protecting natural resources. explore the TNF via car or OHV, there are numerous areas outside of We applied the minimization criteria identified in 36 CFR 212.55(b) to MSO critical habitat that would be more suitable. minimize damage to soil, watershed, vegetation, other Forest resources, and disruption of wildlife habitats to select and evaluate alternatives analyzed in the final EIS. The Mexican spotted owl was analyzed under all alternatives and the biological assessment for effects to the species. Overall, the designations in the draft record of decision will benefit the Mexican spotted owl by eliminating cross- country travel on the Payson and Pleasant Valley ranger districts which encompasses 79% of the Mexican spotted owl critical habitat on the Forest substantially reducing the number of miles of open roads and motorized trails and disturbance from cross-country travel within Mexican spotted owl protected activity centers, cores, and critical habitat; and eliminating year-round disturbance to protected activity centers and cores during nesting and early fledging periods on the Payson and Pleasant Valley ranger districts. The Forest Service is required, as a Federal agency, to consult with U.S. Fish and Wildlife Service and to comply with the Endangered Species Act and promote recovery of a listed species. The biological opinion from U.S. Fish and Wildlife Service concurs with the analysis found in the final EIS and its findings for listed species. Alternatives B, C, and D all reduce the miles of roads in designated critical habitat. A revised alternative C, as described in the final EIS, was analyzed under a biological assessment and consulted on with U.S. Fish and Wildlife Service for MSO and other listed species. Under Alternative C a determination of may effect not likely to adversely affect has been determined and concurred by U.S. Fish and Wildlife Service.

77 Travel Management on the Tonto National Forest

Comment Letter Original Comment Text Forest Service Response Number Roads and trails should avoid streams, rivers, wetlands, and riparian Comment is an opinion and lacks "supporting reasons for the 2472 areas. Unauthorized routes within these areas should not be responsible official to consider" per 36 CFR 218.2. We applied the designated as system routes and should be obliterated, ML1 routes minimization criteria identified in 36 CFR 212.55(b) to minimize should also be closed and decommissioned. Any routes for which the damage to soil, watershed, vegetation, other Forest resources, and Forest Service has suggested administrative use should be allowed disruption of wildlife habitats. Eliminating all routes in close proximity should be thoroughly analyzed for impacts to gartersnake species and to stream and river channels is not a viable alternative. Some routes critical habitat, as well as the reason for administrative use need. are important routes needed for connectivity, and for access to private land, administrative sites, permitted uses, trailheads, etc., and many crossings are hardened or have culverts or bridges. The analysis of all alternatives for stream crossings can be found in the “Hydrological Resources” section of chapter 3 in the final EIS and that report in the project record. All roads within riparian areas were fully analyzed for impacts to the narrow-headed and Mexican gartersnakes within the final Wildlife and Plant Habitat Resources report in the project record, as summarized in the final EIS and in the biological assessment. The analysis includes the species-specific effects from designating a system for motor vehicle use on the Tonto National Forest. ML2-ML5 roads that remain in gartersnake habitat should be designed Comment is an opinion and lacks "supporting reasons for the 2472 and maintained to reduce erosion and sedimentation, minimize responsible official to consider" per 36 CFR 218.2. Analysis of the impacts to gartersnake habitat, and should remain a monitoring and effects of designating a motorized system to listed species, including maintenance priority. the gartersnake, for each alternative can be found in the final Wildlife and Plant Habitat Resources report in the project record, as summarized in the final EIS and in the biological assessment. The designations of the draft record of decision are expected to benefit the species overall by reducing the miles of routes in designated critical habitat, thereby reducing direct effects to the species, as well as reducing habitat degradation. The biological opinion from U.S. Fish and Wildlife Service concurs with the analysis found in the final EIS and its findings for listed species. Road maintenance was analyzed in the “Transportation Facilities” section of chapter 3 of the final EIS. However, species monitoring is outside the scope of this analysis. We encourage the TNF to review potential suitable habitat for the Analysis of the effects of designating a motorized system to listed 2472 ocelot, as well as the newly documented discovery that an ocelot has species, including the ocelot, for each alternative can be found in the been found in Southern Arizona, within the FEIS. Impacts to this final Wildlife and Plant Habitat Resources report in the project record, species must be taken seriously and fully analyzed in light of the as summarized in the final EIS and in the biological assessment. potential presence and establishment of this species on the forest. Overall, the designations on the draft record of decision would benefit

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Comment Letter Original Comment Text Forest Service Response Number the ocelot by reducing access to and activity in potential habitat and in reducing motorized dispersed campsites, reducing human ocelot interactions and degradation of habitat for prey base. The decision is also expected to reduce human ocelot interactions and habitat degradation for prey from motorized use and access which would counteract the long-term impacts of activities concentrated in isolated areas. The Forest Service is required, as a Federal agency, to consult with U.S. Fish and Wildlife Service and to comply with the Endangered Species Act and promote recovery of a listed species. The biological opinion from U.S. Fish and Wildlife Service concurs with the analysis found in the final EIS and its findings for listed species. Camping, states that there would be impacts to approximately 45.37 Discrepancies for the Yuma clapper rail have been reviewed and fixed 2489 acres of potential Yuma clapper rail habitat and Alternative D, under in the analysis in the final EIS. Current limited use to no use of the Big Game Retrieval, would impact 1,997.81 acres of potential Yuma seven analysis factors in the 40.53 acres of potential Yuma clapper clapper rail habitat. Please review and correct these discrepancies. rail habitat on the Forest would have discountable effects to the species. Please address the following inconsistency as it relates to the Wildlife Analysis of the effects of designating a motorized system to listed 2489 and Plant Habitat Resource section for the Yuma Clapper Raif 7 Under species for each alternative can be found in the final Wildlife and Plant Alternative C, Motor Vehicle Use for Dispersed Camping 28 and Habitat Resources report in the project record, as summarized in the Alternative D, Motor Vehicle Use for Big Game Retrieval/ 9 the DEIS final EIS and in the biological assessment. Discrepancies for the notes that there was a total of 16.56 acres 30 of potential Yuma Yuma clapper rail have been reviewed and fixed in the analysis in the clapper rail habitat present on the Forest. Yet, Alternative C, under final EIS. Current limited use to no use of the seven analysis factors in Dispersed. the 40.53 acres of potential Yuma clapper rail habitat on the Forest would have discountable effects to the species. In Chapter 3, Affected Environment, the evaluation of the direct and We applied the minimization criteria identified in 36 CFR 212.55(b) to 2503 indirect effects from implementing the different alternatives should minimize damage to soil, watershed, vegetation, other Forest include all activities being proposed. The environmental effects resources, and disruption of wildlife habitats to select and evaluate discussion under Threatened, Endangered, Candidate, and Sensitive alternatives analyzed in the final EIS. An expanded analysis of the Species primarily describes the total road miles or total number of general, direct, indirect, and cumulative effects of designating a acres associated with motorized activities and how these are more or motorized system to listed, management indicator species, and less than the existing conditions (i.e., how these totals compare with sensitive species for each alternative can be found in the final Wildlife the no action alternative, Alternative A). However, general effects to and Plant Habitat Resources report in the project record, as wildlife and wildlife habitat are only briefly described on page 254 of summarized in the final EIS and in the biological assessment. The the DEIS under the heading General Effects of Motorized Routes and Forest Service is required, as a Federal agency, to consult with U.S. Associated Uses, and on page 39 in the accompanying draft Biological Fish and Wildlife Service and to comply with the Endangered Species Evaluation Report. The effects associated with roads include noise, Act and promote recovery of a listed species. The biological opinion

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Comment Letter Original Comment Text Forest Service Response Number pollution, habitat fragmentation, mortality, loss of connectivity, from U.S. Fish and Wildlife Service concurs with the analysis found in increased edge effects, increased fire risk, and increased risk of the final EIS and its findings for listed species. invasive species. These general effects would also apply to federally listed species and should be incorporated appropriately into their effects evaluations since listed species may also be sensitive to, and likely to experience greater impacts from, some if not all of these factors. SRP requests that no actions be taken that will inhibit our ability to The draft record of decision does not designate any user-created 2489 fulfill our commitments under SRP's ESA Section 10{b) ITP and the roads within the Roosevelt Lake closure area for flycatchers. It does associated RHCP and the H-BHCP for operation of those dams and retain an access road needed by special recreation permit for reservoirs. maintenance. The DEIS does not specifically address proposed actions that may As outlined in the draft record of decision, motorized access within the 2489 occur within the restricted area associated with Forest Service Order closure area will not be permitted, as it will not be designated an OHV 12-167-2R (Willow Flycatcher Closure area). If this Order is to be area nor have motorized routes within it. Other aspects associated rescinded to allow for motor vehicle access and associated activities with the order will be handled outside of this decision. within flycatcher breeding areas and critical habitat, TNF should specifically disclose the action to be taken and address the effects to federally listed and protected species caused by motorized vehicle activity in these areas. Specific measures should be proposed as to how impacts to federally Analysis of the effects of designating a motorized system to listed 2489 listed and protected species will be measured, monitored, and species for each alternative can be found in the final Wildlife and Plant mitigated. Neither the DEIS, nor the associated Biological Evaluation, Habitat Resources report in the project record, as summarized in the detail how impacts will be assessed. The TNF should clearly state how final EIS and in the biological assessment. The Forest Service is monitoring and mitigation or conservation measures will be required, as a Federal agency, to consult with U.S. Fish and Wildlife accomplished. Of particular concern are impacts to flycatchers, as it Service and to comply with the Endangered Species Act and promote received a may affect, likely to adversely affect determination and yet recovery of a listed species. The biological opinion from U.S. Fish and there was no discussion on mitigating or minimizing potential effects. Wildlife Service concurs with the analysis found in the final EIS and its findings for listed species. U.S. Fish and Wildlife Service, through the consultation process, helps address monitoring or mitigations needed for flycatchers in order for the draft record of decision to be in compliance with the Endangered Species Act. These requirements can be found in the biological opinion. Within the Wildlife and Plant Habitat Resource section, for the Between draft and final, alternative C has been further modified to 2489 Southwestern Willow Flycatcher and it's Critical Habitat 7 please address comments that were received. As a result, the wildlife and address the following: Alternative C, Areas Designated for Motor plant habitat resources section in chapter 3 of the final EIS has been Vehicle Use 18 The DEIS states that under Alternative C for the redone. Under alternative A, 219 acres would be available for motor

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Comment Letter Original Comment Text Forest Service Response Number Motorized Vehicle Use Areas, there would be a "decrease in vehicle use, while under alternative C areas designated for motor authorized cross-country motorized use within southwestern willow vehicle use are reduced to 2.92 acres within habitat. For more detailed flycatcher occupied habitat and critical habitat on the Forest." 19 information, see the Threatened and Endangered Species report in However, the same paragraph notes that there would be the project record. approximately 879.35 acres of occupied flycatcher habitat impacted, while Alternative A, the no action alternative, impacts just 320.32 acres 20 of occupied flycatcher habitat. Please address how Alternative C is a decrease in cross-county motor vehicle use if the no action alternative impacts just 320.32 acres while Alternative C impacts 879.35 acres. Alternative C, Motor Vehicle Use for Dispersed Camping 3 The DEIS Between draft and final, alternative C has been further modified to 2489 states that under Alternative C for Dispersed Camping, there would be address comments that were received. As a result, the wildlife and an increase in dispersed camping within occupied flycatcher habitat plant habitat resources section in chapter 3 of the final EIS has been and that this "could result in impacts by increasing access near redone. Under alternative A, no acres would be available for motorized riparian zones, increasing sedimentation into streams, causing dispersed camping, while under alternative C motorized dispersed additional damage to riparian vegetation, and increasing the potential camping could occur on 63 acres within habitat. For more detailed for spreading invasive plants." 24 It would be important to include how information, see the Threatened and Endangered Species report in these impacts will be monitored and mitigated and what conservation the project record. The Forest Service is required, as a Federal measures will be put into place to limit the magnitude of these impacts. agency, to consult with U.S. Fish and Wildlife Service and to comply with the Endangered Species Act and promote recovery of a listed species. The biological opinion from U.S. Fish and Wildlife Service concurs with the analysis found in the final EIS (for the revised alternative C) and its findings for listed species. U.S. Fish and Wildlife Service, through the consultation process, helps address monitoring or mitigations needed for flycatchers in order for the draft record of decision to be in compliance with the Endangered Species Act. These requirements can be found in the biological opinion. Alternative C, Occupied habitat vs. Critical habitat. The comparison of Under the draft EIS occupied habitat was addressed. Due to limited 2489 Alternative C between flycatcher occupied habitat and flycatcher long-term data on flycatcher occupancy the analysis for flycatchers critical habitat raises questions (see table below). For example, zero were analyzed using within, 300 feet and 0.25 miles both critical and acres of critical habitat are impacted for fuelwood gathering (300 feet potential habitat only. Between draft and final, the alternative C has from designated routes), yet 323.54 acres of critical habitat are been further modified to address comments that were received. As a impacted by dispersed camping (100 feet from designated routes). result, the wildlife and plant habitat resources section in chapter 3 of Please review and address flycatcher occupied and critical habitat the final EIS has been redone. Impacts in acres will be reduced or impacted acreages, as there appears to be discrepancies. Alternative non-existent under the modified alternative C and the draft record of C Flycatcher Habitat Impacts Occupied Habitat Critical Habitat Roads decision. This analysis can be found in the final Wildlife and Plant

81 Travel Management on the Tonto National Forest

Comment Letter Original Comment Text Forest Service Response Number and trails open to public use (miles) 30.87 28.15 Areas designated for Habitat Resources report in the project record, as summarized in the motorized cross-country travel (acres) 879.35 0 Motor Vehicle Use for final EIS and in the biological assessment. Big game retrieval (acres) 355.96 15.22 Motor Vehicle Use for Dispersed Camping (acres) 476.07 323.54 Motor Vehicle Use for Fuelwood Gathering (acres) 321.51 0 Alternative C, Motor Vehicle Use for Fuelwood Gathering. Please Fuelwood gathering has been changed from the draft EIS. As 2489 address how Fuelwood Gathering under Alternative C has no impacts indicated in the draft record of decision, no fuelwood gathering will be on flycatcher critical habitat if dispersed camping impacts 323.54 acres allowed in flycatcher habitat. 26 of critical habitat and extends just 100 feet from the roads as opposed to 300 feet from roads for fuelwood gathering. Please address the following discrepancies as they relate to the Between draft and final, the alternative C has been further modified to 2489 Wildlife and Plant Habitat Resource sections for the Western Yellow- address comments that were received. As a result, the wildlife and billed Cuckoo 3 and Southwestern Willow Flycatcher 2 In comparing plant habitat resources section in chapter 3 of the final EIS has been acreages of the proposed actions for impacts to cuckoo habitat and redone. Under alternative A, 219 acres would be available for cross- acreages of the proposed actions for impacts to flycatcher habitat country motor vehicle use, while under alternative C motor vehicle use there appears to be a large disparity. These two species occupy areas are only designated on 2.92 acres within habitat of the relatively similar habitats but the acreages of impact are quite different. southwestern willow flycatcher. Motorized personal use fuelwood For example, under Alternative C, there is a significant difference in gathering would not occur within habitat under either alternative. the acreages identified under "Areas Designated for Motorized Cross- Under alternative A, 214 acres would be available for cross-country country Travel" and under "Motor Vehicle Use for Fuelwood motor vehicle use, while under alternative C motor vehicle use areas Gathering". Under motorized cross-country travel, the Forest Service are not designated within habitat of the cuckoo. Motorized personal notes the greatest amount of impacted flycatcher habitat, but the least use fuelwood gathering would be reduced from 903 acres under amount of impacted cuckoo habitat (see table below). Conversely, alternative A to 166 acres under alternative C. For more detailed under fuelwood gathering, the Forest Service indicates the least information, see the Threatened and Endangered Species report in amount of impacted flycatcher habitat, but the greatest amount of the project record. Though the habitat for these two species are impacted cuckoo habitat (see table below). Please review the similar, there are differences as cuckoos will use more upland areas. acreages and consider reassessing the impacts for these two species. Impacts for these two species have been reassessed under the biological assessment and final EIS which informed the draft record of decision. This analysis can be found in the final Wildlife and Plant Habitat Resources report in the project record, as summarized in the final EIS and in the biological assessment. Please consider including tables in the DEIS with acreage Tables are included in the final Wildlife and Plant Habitat Resources 2489 comparisons for each species by alternative, similar to the Biological report in the project record and in the final EIS with acreage Evaluation, for ease in interpreting numeric data. Alternative C comparisons for all threatened and endangered species. Similar Flycatcher and Cuckoo Habitat Impacts Flycatcher Habitat Cuckoo tables can be found in sections for Forest sensitive species and Habitat Roads and trails open to public use (miles) 30.87 10.55 Areas management indicator species.

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Comment Letter Original Comment Text Forest Service Response Number designated for motorized cross-country travel (acres) 879.35 0.44 Motor Vehicle Use for Big game retrieval (acres) 355.96 117.67 Motor Vehicle Use for Dispersed Camping (acres) 476.07 133.51 Motor Vehicle Use for Fuelwood Gathering (acres) 321.51 188.48 The Forest Service should further limit roads and eliminate cross- Desert tortoises were removed from the candidate list in December of 2472 country travel in desert tortoise habitat. 2015. However, the Sonoran Desert Tortoise Conservation Agreement was developed is which the Tonto National Forest is signatory. The draft record of decision designates a system of motorized routes and areas which will limit routes and eliminate cross- country travel in species habitat and enable the Forest to comply with guidelines laid out in the Conservation Agreement to protect the tortoise. The TNF should incorporate new and pertinent information from the Recent listing for the narrow-headed and Mexican gartersnakes, 2472 recent listing into the EIS and wildlife report. Consultation documents yellow-billed cuckoo and proposed listings for the roundtail and related to the gartersnakes should be released along with any final headwater chub were all included in the analysis for the biological decision. assessment which was sent to U.S. Fish and Wildlife Service for consultation. This analysis can be found in the final Wildlife and Plant Habitat Resources report in the project record, as summarized in the final EIS. All of these documents can be found in the project record. The Forest Service should review the Draft Environmental Impact The revised potential habitat for the Mexican gray wolf was considered 2472 Statement for the Proposed Revision to the Nonessential Experimental in the analysis of impacts under the biological assessment and in the Population of the Mexican Wolf (Canis lupus baileyi) and consider the final Wildlife and Plant Habitat Resources report in the project record, impacts of the proposed travel management plan on this highly as summarized in the final EIS. The draft record of decision endangered animal and on the prey species on which this top predator designates a reduction in roads and motorized trails that will result in depends. reduced potential for wolf human interactions and degradation of prey base habitat. For example, the upper Salt River provides habitat for both golden and Between draft and final, the alternative C has been further modified to 2503 bald eagles, both protected under the Bald and Golden Eagle address comments that were received. As a result, the wildlife and Protection Act. Cottonwood-willow riparian forests and mixed broadleaf plant habitat resources section in chapter 3 of the final EIS has been deciduous riparian forest support many of these species, yet redone. Cross country travel no longer occurs under this alternative information presented in Table 56 (Miles of Roads and Road Density and only a small portion of a permit area occurs within flycatcher in Each PNVT and Acres of Each PNVT Impacted by Five Analysis habitat which is a decrease of 99% from current. Effects from Factors under Each Alternative) suggests that impacts to these motorized use like sedimentation, habitat degradation and human vegetation communities either from cross-country travel or adding disturbance were all analyzed under alternative C in the “Wildlife and miles of open roads and trails will increase under the implementation Plant Habitat Resources” section of the final EIS and in the biological of Alternative C. While the DEIS states Alternative C could have assessment for the listed species like the flycatcher. Bald and golden

83 Travel Management on the Tonto National Forest

Comment Letter Original Comment Text Forest Service Response Number effects to bald eagle habitat quality but is not anticipated to have a eagles are analyzed in the “Migratory Birds” section where effects measurable and detectible effect on habitat quality of the cottonwood- from the draft decision are described. willow riparian forest PNVT, the analysis for the southwestern willow flycatcher states this alternative could increase access near riparian zones, increase sedimentation into streams, cause additional damage to riparian vegetation, and increase the potential for spreading invasive plants. We understand the Tonto NF must balance different land uses. However, we highly recommend you reconsider motorized cross- county uses in these areas in order to protect or maintain the functionality, structure, and quality of riparian forests. Increased impacts will continue to degrade and fragment these areas, which may result in negative effects to the listed or proposed species that rely on these habitats for their persistence. Table 56 (pages 251˗254) of the DEIS identifies total road miles and Potential natural vegetation type was used for analysis of 2503 road density within each Potential Natural Vegetation Type (PNVT) management indicator species. For listed species, designated habitat and the total acreage of each PNVT affected by Alternative C. In according to the U.S. Fish and Wildlife Service, whether critical, general, we recommend the effects evaluation for all listed or potential or proposed, was utilized from the Tonto National Forest’s proposed species incorporate information that is provided in Table 56. GIS database. Habitat designated by U.S. Fish and Wildlife Service is The discussion should describe how this information relates to impacts the required habitat to be analyzed in the consultation process for on listed species and their habitats, in conjunction with the general listed species. Impacts to listed species and their habitat were effects listed above. However, the majority of the listed species evaluated for each alternative in the final EIS and for the modified included in the DEIS have habitat found within streams, rivers, or alternative C the biological assessment. The motorized system riparian communities. designated in the draft record of decision reflects the analysis for the modified alternative C. Lastly, although the timeframe or lifespan of the Travel Management Under the “Public Comments on the Proposed Rule and Department 2503 Project is not clearly stated in the document, any effects to listed Responses” section of the 2005 Travel Management Rule (Federal species should take the following into consideration: changing climatic Register, Volume 70, Number 216 1192015, page 68283) states patterns and their foreseeable impact on native vegetation and water "Since the system of designated routes and areas will change over availability; increases or decreases in off-highway vehicle use or time, the Department anticipates that local units will publish new motor hunting opportunities; the probability of natural areas to recover from vehicle use maps annually and update signs as necessary or impacts associated with cross-country travel; and changes in the appropriate.” The designated roads, motorized trails, and areas will be quality of species habitat over time. reviewed annually. There is no time frame under the rule for travel management where designations in the decision would expire. As the need arises, individual projects may arise which would then require separate analysis under the National Environmental Policy Act and the consultation under the Endangered Species Act. For this travel

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Comment Letter Original Comment Text Forest Service Response Number management analysis, a period of 10 years was chosen as a timeframe in which consultation would be reinitiated with U.S. Fish and Wildlife Service to account for changes that could affect listed species such as changes in climate, quality of species habitat over time, etc. The DEIS identifies seventeen federally endangered, threatened, or Analysis of the effects of designating a motorized system to listed 2503 proposed species, as well as proposed or designated critical habitat species for each alternative can be found in the final Wildlife and Plant for eight of those species on the Tonto National Forest. Some of the Habitat Resources report in the project record, as summarized in the listed species, such as the threatened Mexican spotted owl final EIS and in the biological assessment. The Forest Service is (Strixoccidentalislucida), threatened Chiricahua leopard frog required, as a Federal agency, to consult with U.S. Fish and Wildlife (Lithobates chiricahuensis), and endangered southwestern willow Service and to comply with the Endangered Species Act and promote flycatcher (Empidonax trailliiextimus), have occupied habitat in various recovery of a listed species and maintain or improve habitat for the areas and in more than one Ranger District. The implementation of recovery of the species. Alternative C has been modified from the Alternative C may result in an increase in potential impacts to listed draft EIS. Overall, impacts are reduced to listed species under the species that affect the species forest-wide. revised alternative C. This is also the alternative which was consulted on with U.S. Fish and Wildlife Service. The biological opinion from U.S. Fish and Wildlife Service concurs with the analysis found in the final EIS and its findings for listed species. SRP requests that the Forest Service revise the current draft to On February 18, 2015, the Tonto National Forest met with special 2489 appropriately analyze and consider the impacts authorization of cross- recreation permit representatives to discuss their concerns regarding country travel will have on SRP's ITPs and associated HCPs, because their motorized access to conduct activities associated with powerline these permits secure SRP's ability to store water in the reservoirs. management, along with their concern over the size and location of the proposed designated OHV area in the preferred alternative related to Roosevelt Lake. As shown in the draft record of decision, a substantially smaller OHV area associated with Roosevelt Lake will be designated, in order to minimize the effects of motor vehicle use on natural resources, including southwestern willow flycatcher habitat. This was also done to respect the existing permits that special recreation permit has with the U.S. Fish and Wildlife Service related to incidental take permits and the Roosevelt Habitat Conservation Plan. The Forest Service should eliminate roads and trails within water Comment is an opinion and lacks "supporting reasons for the 2472 habitat within any final travel management plan. responsible official to consider" per 36 CFR 218.2. We applied the minimization criteria identified in 36 CFR 212.55(b) to minimize damage to soil, watershed, vegetation, other forest resources, and disruption of wildlife habitats. Eliminating all routes in close proximity to stream and river channels is not a viable alternative. Some routes are important routes needed for connectivity, and for access to private

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Comment Letter Original Comment Text Forest Service Response Number land, administrative sites, permitted uses, trailheads, etc., and many crossings are hardened or have culverts or bridges. Alternative B had the least amount of stream crossings, motor vehicle use in riparian areas, and in close proximity to stream channels. The analysis of all alternatives for stream crossings can be found in the “Hydrological Resources” section of chapter 3 in the final EIS and that report in the project record. Effects to species habitat quality, including water habitats can be found in the “Wildlife and Plant Habitat Resources” section of the final EIS. Because of the lack of information as to the status, spread, or location Comment is an opinion and lacks "supporting reasons for the 2472 of these cacti, the TNF should include within the final travel responsible official to consider" per 36 CFR 218.2. Analysis of the management plan direction to locate individual hedgehog cacti during effects of designating a motorized system to listed species for each maintenance and monitoring activities. In the future, when a cactus is alternative can be found in the final Wildlife and Plant Habitat identified near a motorized route, protections for that cactus should be Resources report in the project record, as summarized in the final EIS implemented. If motorized routes become a known source of intrusion and in the biological assessment. The Forest Service is required, as a into hedgehog habitat, or are located in an areas where a cacti has Federal agency, to consult with U.S. Fish and Wildlife Service and to been damaged or destroyed, that motorized use should be curtailed comply with the Endangered Species Act and promote recovery of a through route closure and enforcement. listed species and maintain or improve habitat for the recovery of the species. Alternative C has been modified from the draft EIS. Overall, impacts are reduced to listed species under the revised alternative C. This is also the alternative which was consulted on with U.S. Fish and Wildlife Service. The biological opinion from U.S. Fish and Wildlife Service concurs with the analysis found in the final EIS (for the revised alternative C) and its findings for listed species. U.S. Fish and Wildlife Service, through the consultation process, helps address monitoring or mitigations needed for Arizona hedgehog cactus in order for the draft record of decision to be in compliance with ESA. These requirements can be found in the biological opinion. The designations in the draft record of decision are expected to benefit the Arizona hedgehog cactus by reducing miles of routes and road density, reducing the chance of crushing plants. Reducing overall road density also reduces soil compaction. Motorized vehicle use for big game retrieval would be limited in potential hedgehog habitat, also reducing the potential of crushing plants or compacting soil. Route maintenance is analyzed in the “Transportation Facilities” section of the final EIS.

86 Volume II–Response to Comments

Soils and Water Resources Comment Letter Original Comment Text Forest Service Response Number Make stream and river banks off limits. We applied the minimization criteria identified in 36 CFR 212.55(b) to 24 minimize damage to soil, watershed, vegetation, other Forest resources, and disruption of wildlife habitats. Eliminating all routes in close proximity to stream and river channels is not a viable alternative. Some routes are important routes needed for connectivity, and for access to private land, administrative sites, permitted uses, trailheads, etc., and many crossings are hardened or have culverts or bridges. Alternative B had the least amount of stream crossings, motor vehicle use in riparian areas, and in close proximity to stream channels. The analysis of all alternatives for stream crossings can be found in the “Hydrological Resources” section of chapter 3 in the final EIS and that report in the project record. We ask the TNF to look at the Watershed Condition Framework (a Much of the water resources discussion in the final Hydrological 2471 U.S. Forest Service product) plan and analysis for more information Resources report in the project record and in the final EIS is based on and assistance with the analysis of the impacts of motorized routes to an analysis of the roads and trails condition indicator in the Watershed the TNF. Further, we ask the TNF to decommission routes that cause Condition Classification Technical Guide (USDA FS 2011a). This or contribute to riparian degradation. guide implements the direction provided in the Watershed Condition Framework (USDA FS 2011b) that the commenter is referencing. Open road density and proximity to water (two of the attributes used to derive the roads and trails indicator rating in the Watershed Condition Classification) are evaluated for each alternative. The miles of roads in riparian areas and the number of stream crossings are also assessed for each alternative. The miles of motorized routes that cause or contribute to riparian degradation vary by alternative. Motorized routes in riparian areas that are not designated for motor vehicle use in the final Travel Management Decision will be prioritized for decommissioning. Separate environmental analyses will be completed prior to any motorized route decommissioning and rehabilitation projects in compliance with the National Environmental Policy Act. In order to combat the negative effects of off-road vehicle use on water We applied the minimization criteria identified in 36 CFR 212.55(b) to 2472 quality, the Forest Service should close and decommission any OHV minimize damage to soil, watershed, vegetation, and other Forest trails that cross streams or are near riparian areas where damage to resources, and disruption of wildlife habitats when including a route as riparian or aquatic ecosystems is occurring or where off-trail use into a motorized trail. Eliminating all motorized trails in close proximity to streambeds, streambanks, or running water is occurring. stream and river channels is not a viable options as some of these

87 Travel Management on the Tonto National Forest

Comment Letter Original Comment Text Forest Service Response Number route provide connectivity, and for access to private land, administrative sites, permitted uses, trailheads, etc., and some crossings are hardened or have culverts or bridges. We have draft an implementation plan for motorized trail maintenance that addresses trail engineering and decreasing impacts to water quality and other resources. We have also identified several organizations to partner with to help implement and maintain the motorized trail system. Motorized routes in riparian areas that are not designated for motor vehicle use in the final Travel Management Decision will be prioritized for decommissioning. Separate environmental analyses will be completed prior to any motorized route decommissioning and rehabilitation projects in compliance with the National Environmental Policy Act. The TNF should include monitoring provisions for aquatic and riparian We applied the minimization criteria identified in 36 CFR 212.55(b) to habitat near motorized routes or trails that could potentially provide minimize damage to soil, watershed, vegetation, and other Forest unauthorized access to rivers or streams within the forest. resources, and disruption of wildlife habitats when including a route as Safeguarding these areas is of particular importance to protecting a motorized trail. Appendix F of the draft implementation plan for wildlife diversity, drinking water resources, and preventing the motorized trails identifies monitoring needs and proposed timelines for establishment of exotic, invasive riparian plants that have become accomplishing the work. The main focus of this appendix is education, widespread throughout the region. particularly with keeping signs that discourage resource damage in place and functional. Education of users about the provisions of the final decision and enforcement of these provisions will be critical to preventing proliferation of new unauthorized routes near aquatic and riparian habitat, as well as elsewhere on the Forest. The Tonto National Forest has also identified several organizations to partner with to help implement and maintain the motorized trail system, including signs. This would also apply to roads where education and enforcement of the final decision is important. Periodically, road condition surveys are conducted on the Forest. When erosion issues are identified, the road is repaired as resources are available. In addition, the Forest conducts monitoring using best management practices associated with roads, including the use of culverts, lead-off ditches, low water crossings, and water bars, and corrects them if they are not functioning to decrease effects to resources. Motorized routes in riparian areas that are not designated for motor vehicle use in the final Travel Management Decision will be prioritized for decommissioning. Separate environmental analyses will be completed

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Comment Letter Original Comment Text Forest Service Response Number prior to any motorized route decommissioning and rehabilitation projects in compliance with the National Environmental Policy Act. Additional information about the effects to these resources from the designation of a motorized route system can be found in chapter 3 of the final EIS. Describe the actions that the Forest Service will take should OHV The watershed above the section of the Salt River that the commenter 2504 travel be found as a major contributor to the impaired designation of is referring to is approximately 4,300 square miles, and the entire Salt the Salt River between the confluence with Pinal Creek and Roosevelt River crosses through several jurisdictions before it enters the Tonto Lake. National Forest. Should sediment from motorized roads and trails within the Forest be found to be a major contributor to the impaired designation in this reach of the Salt River in the total maximum daily load analysis completed by Arizona Department of Environmental Quality, recommendations would be provided to the Forest for how to reduce the sediment loading to the Salt River from motorized routes. In the past, the Tonto National Forest has often followed these recommendations and contributed to the effort to decrease the source of pollution. Decommissioning or restricting access to routes found to be contributing pollutants to this section of the Salt River would be considered with a separate environmental analyses in compliance with the National Environmental Policy Act. It would also provide impetus for improving existing best management practices or implementing additional best management practices on routes designated as open for motorized use within these watersheds. Include monitoring provisions within the final TMP that specifically We applied the minimization criteria identified in 36 CFR 212.55(b) to 2472 focus on areas where motorized trails, routes, or areas cross or minimize damage to soil, watershed, vegetation, and other Forest provide access to streams and rivers. resources, and disruption of wildlife habitats when including a route as a motorized trail. Appendix F of the draft implementation plan for motorized trails identifies monitoring needs and proposed timelines for accomplishing the work. The main focus of this appendix is education, particularly with keeping signs that discourage resource damage in place and functional. Education of users about the provisions of the final decision and enforcement of these provisions will be critical to preventing proliferation of new unauthorized routes near aquatic and riparian habitat, as well as elsewhere on the Forest. The Tonto National Forest has also identified several organizations to partner with to help implement and maintain the motorized trail system,

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Comment Letter Original Comment Text Forest Service Response Number including signs. This would also apply to roads where education and enforcement of the final decision is important. Periodically, road condition surveys are conducted on the Forest. When erosion issues are identified, the road is repaired as resources are available. In addition, the Forest conducts monitoring using best management practices associated with roads, including the use of culverts, lead-off ditches, low water crossings, and water bars, and corrects them if they are not functioning to decrease effects to resources. Motorized routes in riparian areas that are not designated for motor vehicle use in the final Travel Management Decision will be prioritized for decommissioning. Separate environmental analyses will be completed prior to any motorized route decommissioning and rehabilitation projects in compliance with the National Environmental Policy Act. Additional information about the effects to these resources from the designation of a motorized route system can be found in chapter 3 of the final EIS. Describe, in the FEIS, the BMPs and other mitigation measures that A list of best management practices that could potentially be used for 2504 could be implemented where unauthorized routes proposed for preventing or minimizing impacts to hydrologic and aquatic resources inclusion into the National Forest Transportation System are having from unauthorized routes proposed for inclusion into the motorized disproportionate impacts upon hydrologic and aquatic resources, and system is included in appendix C of the final Hydrological Resources explain how the Forest Service will determine where and when to report in the project record. Unauthorized routes designated as apply such measures. motorized routes will be brought up to Forest Service standards for the designated maintenance level. For motorized trails, we have draft an implementation plan for maintenance that addresses trail engineering and decreasing impacts to water quality and other resources. We have also identified several organizations to partner with to help implement and maintain the motorized trail system. The location of best management practices and timing for implementing them would be decided on a case-by-case basis under a separate environmental analyses in compliance with the National Environmental Policy Act. Describe, in the FEIS, the status of such consultation, and provide the The Tonto National Forest’s final travel management decision will 2504 acres of waters that would be affected by the proposed action. designate a system of motorized roads, trails, and areas in compliance with the final Travel Management Rule (36 CFR 212). This action does not propose any surface disturbing activities that would impact jurisdictional waters. Once the final Travel Management Decision is signed, separate environmental analysis, in compliance with the

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Comment Letter Original Comment Text Forest Service Response Number National Environmental Policy Act, will be necessary for projects proposed to decommission routes no longer included in the motorized system and for projects needed to bring unauthorized routes that are included in the motorized system up to Forest Service standards. The U.S. Army Corps of Engineers will be consulted on project proposals that would result in discharge of dredge or fill material into jurisdictional waters. EPA recommends that the TNF consult with the USACE regarding the The Tonto National Forest’s final Travel Management Decision will 2504 extent of jurisdictional waters on the project site and the potential designate a system of motorized roads, trails, and areas in compliance impacts to such waters from Travel Management related actions. with the final Travel Management Rule (36 CFR 212). This action does not propose any surface disturbing activities that would impact jurisdictional waters. Once the final Travel Management Decision is signed, separate environmental analysis, in compliance with the National Environmental Policy Act, will be necessary for projects proposed to decommission routes no longer included in the motorized system and for projects needed to bring unauthorized routes that are included in the motorized system up to Forest Service standards. The U.S. Army Corps of Engineers will be consulted on project proposals that would result in discharge of dredge or fill material into jurisdictional waters. In addition, desert and semi-desert lands have fragile soils. Once Comment is an opinion and lacks "supporting reasons for the 2215 those topsoils are disturbed, it takes more than 2+ generations to responsible official to consider" per 36 CFR 218.2. However, rehabilitate or regenerate. Erosion of soils should be of prime concern accelerated erosion resulting from human activities is a concern to the to the Forest Service. Forest, regardless of the cause. When accelerated erosion is identified, we implement best management practices to eliminate, reduce, or mitigate the effects to water quality. For designation of a motorized system of routes and areas, we applied the minimization criteria identified in 36 CFR 212.55(b) to minimize damage to soil, watershed, vegetation, and other Forest resources, and disruption of wildlife habitats when recommending motorized routes to remain open. Effects to soils from designating motorized routes and areas for all alternatives can be found in the “Soil Resources” section of the final EIS. Erosion should not be considered a horrible consequence, erosion is Comment is an opinion and lacks "supporting reasons for the 2482 what has made this state so spectacular. responsible official to consider" per 36 CFR 218.2. There is no doubt that natural erosion processes have created spectacular features both

91 Travel Management on the Tonto National Forest

Comment Letter Original Comment Text Forest Service Response Number on the Forest and in the State. The Forest actively works to prevent or minimize accelerated erosion that is caused by human activities. Accelerated erosion can cause water quality and channel stability problems in affected streams. It can also reduce productivity of upland sites where the erosion is occurring. For designation of a motorized system of routes and areas, we applied the minimization criteria identified in the final Travel Management Rule (36 CFR 212.55(b)) to minimize damage to soil, watershed, vegetation, and other Forest resources, and disruption of wildlife habitats when recommending motorized routes to remain open. Effects to soils from designating motorized routes and areas for all alternatives can be found in the “Soil Resources” section of the final EIS.

92 Volume II–Response to Comments

Air Quality Comment Letter Original Comment Text Forest Service Response Number Please provide the EPA scientific source and year on climate change The date of publication is November 2006. The correct citation will be 1 as part of the discussion under the Climate Change Effects on Future revised in the final EIS. Air Quality Section or under its Scientific Sources section. Under the Climate Change Effects on Future Air Quality This comment is an opinion and lacks specific information and 1 Section/discussion beginning on page 20 of 35. Discussion about U.S. "supporting reasons for the responsible official to consider" per 36 Environmental Protection Agency (USEPA) on climate change is not CFR 218.2. No further response warranted. robust and convincing. Under the Scientific Sources section, please provide the year on the The date of publication is November 2006. The correct citation has be 1 Scientific Source: "Compilation of Air Pollutant Emission Factors. corrected in the final EIS. Volume 1, Fifth Edition: Miscellaneous Sources. EPA AP-42 Chapter 13.2.2." The DEIS should have identified and analyzed an alternative that The General Conformity Rule ensures that the actions taken by 2472 includes mitigation measures that clearly demonstrate compliance with Federal agencies in nonattainment and maintenance areas do not NAAQS and Prevention of Serious Deterioration increments and interfere with a state’s plans to meet national standards for air quality. assure there will be no adverse impacts on air quality related values. (USEPA 2015). The requirements under 40 CFR Part 93, Subpart B “Determining Conformity of General Federal Actions to State or Federal Implementation Plans” do not apply to Federal actions which would result in no emissions increase or an increase in emissions that is clearly de minimis (see 40 CFR 93.153). The Prevention of Significant Deterioration (PSD) permitting program is a Clean Air Act permitting program for new and modified major sources of air pollution such as power plants, manufacturing facilities, and other facilities that emit "major" and "significant" amounts of air pollution for any criteria pollutant. It also applies to modifications at existing plants that lead to increases of air pollution that will be "major" or "significant". "Major" means emitting or having the potential to emit 100 tons per year (tpy) or more of any criteria pollutant for the specific source categories listed in the PSD regulations. (USEPA 2015). Compliance with the National Ambient Air Quality Standards (NAAQS) and with SIP approved permitting programs, like the PSD program (if required), is presumed. Tonto National Forest demonstrated, using thresholds specified under 40 CFR 93.153(b), that emissions from the Tonto National Forest Travel Management Plan (TMP) are de minimis.

93 Travel Management on the Tonto National Forest

Comment Letter Original Comment Text Forest Service Response Number Thresholds for PM10 emissions under 40 CFR 93.153(b) are more stringent than PSD thresholds for nonattainment areas classified as serious for PM10, 70 tons per year for GC vs 100 tons per year for PSD. According to 40 CFR 93.153(b) and 40 CFR 93.153(g), the Travel Management Plan is presumed to conform to a SIP for each criteria pollutant identified in 40 CFR 93.153(b)(1) and (b)(2) and in the National Ambient Air Quality Standards (NAAQS) under 40 CFR 50.4– 50.12. More information can be found in the final Air Quality report in the project record and summarized in chapter 3 of the final EIS. The DEIS does not include a detailed dispersion modeling assessment This analysis has been completed and shows that all of the action 2472 of the impacts of the proposed action on compliance with the NAAQS, alternatives (alternatives B, C, and D) show improvement over the on whether there will be significant deterioration of air quality and on current condition (alternative A). Compliance with the National whether there will be significant visibility impacts, nor is there an Ambient Air Quality Standards (NAAQS) and with state acceptable explanation as to why this assessment was not completed. implementation plan (SIP) approved permitting programs, like the Prevention of Significant Deterioration (PSD) program (if required), is presumed. Tonto National Forest demonstrated, using thresholds specified under 40 CFR 93.153(b), that emissions from the Tonto National Forest Travel Management Plan (TMP) are de minimis. Thresholds for PM10 emissions under 40 CFR 93.153(b) are more stringent than PSD thresholds for nonattainment areas classified as serious for PM10, 70 tons per year for GC vs 100 tons per year for PSD. According to 40 CFR 93.153(b) and 40 CFR 93.153(g), the travel management plan is presumed to conform to a SIP for each criteria pollutant identified in 40 CFR 93.153(b)(1) and (b)(2) and in the National Ambient Air Quality Standards (NAAQS) under 40 CFR 50.4– 50.12. More information can be found in the final Air Quality report in the project record and summarized in chapter 3 of the final EIS. Additional air quality analysis should be performed and included in the Applicability analysis indicates that emissions for all of the nine study 2504 FEIS to more clearly demonstrate that the project would not negatively areas are below de minimis thresholds specified under 40 CFR affect air quality, exceed de minimis thresholds or contribute to an 93.153(b). In addition, the requested NAAQS analysis has been exceedance of the NAAQS. Consideration should be given to the conducted and shows that the actions proposed will not cause or spatial distribution of OHV use before and after the proposed actions contribute to a violation of the NAAQS. More information can be found and any potential consequences thereof upon local air quality. in the final Air Quality report in the project record and summarized in chapter 3 of the final EIS. The FEIS should include a separate NAAQS analysis. If dispersion Applicability analysis indicates that emissions for all of the nine study 2504 modeling is deemed infeasible, the FEIS should discuss alternative areas are below de minimis thresholds specified under 40 CFR

94 Volume II–Response to Comments

Comment Letter Original Comment Text Forest Service Response Number approaches. For example, does an appropriate analog site exist where 93.153(b). In addition, the requested NAAQS analysis has been air quality monitoring has occurred in proximity to OHV recreation? conducted and shows that the actions proposed will not cause or contribute to a violation of the NAAQS. This analysis is detailed in the final Air Quality report in the project record and summarized in chapter 3 of the final EIS. The Air Quality Specialist Report appears to be rather outdated. The Conformity determinations are requirements imposed on Federal 2472 Air Quality Specialist Report is signed and dated March 24, 2014. agencies by the Clean Air Act (CAA). Where a determination of However, the content of the report appears to pre-date 2013 conformity is required, it shall be based on the most recent estimates of emissions, as determined by the Metropolitan Planning Agency. (40 CFR Part 93, subpart B). Tonto National Forest estimated emissions for each criteria pollutant using the most recent and conservative data available. Otherwise, the assumptions made in the calculation of the emissions estimates used in the for the air quality analysis were adopted from the Maricopa Association of Governments (MAG) 2012 Five Percent Plan and the most recent emissions inventory containing PM10 emissions from off-road recreation vehicles, titled Revised 2011 Periodic Emission Inventory for PM-10 for the Maricopa County, Arizona, Nonattainment Area (PEI-2011) (MCAQD 2011). More information can be found in the final Air Quality report in the project record and summarized in chapter 3 of the final EIS. The air quality analysis is deeply flawed and such flawed analysis has Comment is an opinion and lacks "supporting reasons for the 2472 led to the erroneous determination that there will be a reduction in responsible official to consider" per 36 CFR 218.2. However, the Tonto emissions, including PM10, for each action alternative. DEIS Air National Forest estimated emissions for each criteria pollutant using Quality Specialist Report at 34. This incorrect determination is then the most recent and conservative data available. Otherwise, the used to incorrectly find that a General Conformity Determination assumptions made in the calculation of the emissions estimates used (GCD) is not required. DEIS at 490. Because the baseline for the for the air quality analysis were adopted from the Maricopa analysis results in a flawed determination of reduced emissions, the Association of Governments (MAG) 2012 Five Percent Plan and the finding that a GCD is not required is also flawed. Thus, the TNF most recent emissions inventory containing PM10 emissions from off- cannot assert that route designations will result in de minimus or road recreation vehicles, titled Revised 2011 Periodic Emission reduced emissions. Inventory for PM-10 for the Maricopa County, Arizona, Nonattainment Area (PEI-2011) (MCAQD 2011). Based on the available data, emissions from the Tonto National Forest Travel Management Plan (TMP) either do not increase with respect to baseline emissions or are de minimis according to 40 CFR 93.153(b). This analysis is detailed in the final Air Quality report in the project record and summarized in chapter 3 of the final EIS.

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Comment Letter Original Comment Text Forest Service Response Number Therefore the TNF must, after correcting the baseline information used Federal projects are exempt from submitting a conformity 2472 for the air quality analysis, make a GCD and inform the public how the determination if the General Conformity Applicability Analysis shows route designations for this project will conform to SIPs. This that total direct and indirect emissions of the criteria pollutants or necessarily requires a significant reduction in the number of motorized precursors are de minimis, according to emission threshold screening routes designated as open to the public. A failure to do so will result in criteria specified under 40 CFR 93.153(b)(1) and (2). The results of the a violation of NAAQS and a violation of the Clean Air Act. applicability analysis, which indicate that emissions for all of the nine study areas are below de minimis thresholds, exempts this project from a conformity determination. This analysis is detailed in the final Air Quality report in the project record and summarized in chapter 3 of the final EIS. Also discussed, are the effects of designating varying amounts of motorized routes and areas on air quality in the analysis of all action alternatives (alternatives B, C, and D). The FEIS should be revised to appropriately characterize the results of Applicability analysis indicates that emissions for all of the nine study 2504 the air quality analysis performed. areas are below de minimis thresholds specified under 40 CFR 93.153(b). In addition, the requested NAAQS analysis has been conducted and shows that the actions proposed will not cause or contribute to a violation of the NAAQS. This analysis is detailed in the final Air Quality report in the project record and summarized in chapter 3 of the final EIS. Much of the Phoenix area suffers from high pollution levels, including The air quality analysis indicates that all of the action alternatives 1101 particulate pollution. Dust generated by off-road vehicles exacerbates (alternatives B, C, and D) show improvement over the current this problem. Please develop a final alternative that minimizes dust in condition. Baseline and future emissions of PM10, NOx and VOC from order to better protect public health, as well the plants and animals off-highway vehicles (OHV) were examined for geographic areas of affected by excessive dust. the Tonto National Forest deemed acutely sensitive to increases of air pollutant emissions. Five air quality planning areas were identified, including three 24-hour PM10 nonattainment areas, one 24-hour PM10 maintenance area and one area classified as nonattainment for ozone. The analysis indicated that emissions due to the Tonto National Forest Travel Management Plan either do not increase with respect to baseline emissions or are de minimis according to 40 CFR 93.153(b). This analysis is detailed in the final Air Quality report in the project record and summarized in chapter 3 of the final EIS. In addition to the four Class I areas within the TNF that are identified in Mount Baldy Wilderness, Petrified Forest National Park, and Galiuro 2472 the DEIS (Pine Mountain Wilderness, Mazatzal Wilderness, Sierra Wilderness areas are outside of the study area. The study area Ancha Wilderness, and Superstition Wilderness), the TNF must also included key locations within the Tonto National Forest administrative consider any potential air quality impacts from the proposed action and boundary and class I areas located within the geographic boundaries

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Comment Letter Original Comment Text Forest Service Response Number alternatives to air quality related values in the nearby Mount Baldy of the Lower Slat River or Verde River airsheds. The USDA Natural Wilderness (USFS), Petrified Forest National Park (National Park Resources Conservation Service defines an airshed “as part of the Service) and Galiuro Wilderness (USFS) Class I areas. atmosphere that behaves in a coherent way with respect to the dispersion of emissions.” And “typically forms an analytical or management unit for air quality standards.” The potential for significant PM10 impacts to the Mount Baldy Wilderness, Petrified Forest National Park, and Galiuro Wilderness areas from OHV activities at the Tonto National Forest are expected to be minimal. This is because these wilderness areas are located outside the Tonto border (approximate distances of 50 to 100 miles from the Tonto National Forest) and outside of the airsheds where the Tonto National Forest resides. After an accurate and correct analysis of air quality is completed, if Tonto National Forest estimated emissions for each criteria pollutant 2472 such information reveals OHV use is contributing or will contribute to using the most recent and conservative data available. Otherwise, the air quality problems in the Phoenix area, the Forest Service must assumptions made in the calculation of the emissions estimates used reduce the amount of OHV use allowed on the Forest and locate in the for the air quality analysis were adopted from the Maricopa routes on which OHVs can travel in such a way as to minimize Association of Governments (MAG) 2012 Five Percent Plan and the contributions to air quality problems. most recent emissions inventory containing PM10 emissions from off- road recreation vehicles, titled Revised 2011 Periodic Emission Inventory for PM-10 for the Maricopa County, Arizona, Nonattainment Area (PEI-2011) (MCAQD 2011). Based on the available data, emissions from the Tonto National Forest Travel Management Plan (TMP) either do not increase with respect to baseline emissions or are de minimis according to 40 CFR 93.153(b). This analysis is detailed in the final Air Quality report in the project record and summarized in chapter 3 of the final EIS. Also discussed, are the effects of designating varying amounts of motorized routes and areas on air quality in the analysis of all action alternatives (alternatives B, C, and D). The DEIS indicates the Forest receives approximately 5 million visitors After closely reviewing the 2004 report by Dr. English, Tonto National 2498 annually, a million of whom recreate using off-highway vehicles Forest has determined that the OHV participation rate of “one million (OHV).1, 2 If that is accurate, then estimates of daily OHV traffic visitors using OHVs on the Forest annually” was misstated. According displayed in Table 79 are inaccurate by an order of magnitude. Since to English (2004), the OHV participation rate for Tonto National Forest the calculation of emissions of particulate matter (PM10) and ozone- is 948,504 visits from January 1, 2000, to September 30, 2003, forming chemicals is substantially influenced by the amount of OHV (approximately 3.75 years as opposed to annually). The 2004 report traffic, I recommend the analysis incorporate better data on OHV use published by Dr. English, titled Off-Highway Vehicle Use on National

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Comment Letter Original Comment Text Forest Service Response Number Forests: Volume and Characteristics of Visitors, states that “The first sampling cycle occurred from January 1, 2000 to September 30, 2003.” The final EIS has been revised for the section tilted “Background of Motor Vehicle Use and Management on the Tonto National Forest” to read “with OHV participation of nearly a million visitors from January 1, 2000 to September 30, 2003 (English et al. 2004).”

The DEIS asserts that Alternatives B, C, and D would substantially The quantified estimates of the net change in PM10 emissions from 2498 reduce fugitive dust and ozone-forming emissions from the baseline OHV use are presented in the final Air Quality report in the project (page 488). It would be helpful to present quantified estimates for all record, and summarized in chapter 3 of the final EIS. Emissions are alternatives, to support that assertion. Further, the analysis would be listed for each alternative by planning area within the Forest and show stronger if it dealt directly with this issue of motorized recreation on that there is no significant increase in fugitive dust or precursors to federal lands contributing to air pollution. ozone for alternatives B, C, and D when compared to the baseline (alternative A). The air quality section references state-level planning for enhanced According to A.R.S. § 49-457.05, the Dust Action General Permit 2498 protection of Class I federal lands, which on the Forest comprises four specifies best management practices (BMPs) aimed at reducing wilderness areas. I recommend the discussion cite the state’s Dust particulate emissions (PM10) from regulated activities occurring within Action General Permit, if the Forest is a potential permittee. The any serious PM10 nonattainment area and on days when the Arizona General Permit specifies a set of management practices that apply to Department of Environmental Quality issues a high pollution advisory designated, managed, or open trail systems during high-wind events. (HPA) for PM10. Under the statute, episodic best management practices are to be implemented by certain dust-generating activities on days that are high risk for dust generation per the air quality dust forecast issued by the Arizona Department of Environmental Quality. A Requirement to Operate (RTO) under the dust action general permit may be required for an owner or operator that fails to implement a BMP as per the statute (A.R.S. § 49-457.05). Compliance with § 49- 457.05 is mandatory for most, but not all, dust-generating operations, including recreational use of off-highway vehicles within designated, managed or opened trail systems. Emergency activities and farm cultural practices which cause dust are also not regulated activities under the statute. (See A.R.S. §§ 49-504(4) or 49-457 and ARS § 49- 504(k)(1)). With respect to recreational use of off-highway vehicles, Tonto National Forest employs the following managements VIII of the Dust Action General Permit: 1. Posting public information about restriction of operation during high pollution advisories; and 2. Restriction of

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Comment Letter Original Comment Text Forest Service Response Number operation during high pollution advisories; gates to permit areas are locked to prevent use during pollution advisory days. Further, particulate emissions from unauthorized cross-country travel would be eliminated due to prohibition of motorized cross-country travel under alternatives B, C and D; each of which also eliminate a varying number of miles of unauthorized unpaved routes within the Tonto National Forest. As seen in alternative A, the Tonto National Forest currently allows motorized cross-country travel throughout the Forest except in three types of areas: congressionally designated wilderness, areas closed to motorized use in the Forest Plan, or areas closed to motorized use in a Forest closure order. In comparison, the MAG 2012 Five Percent Plan for PM10 for the Maricopa County nonattainment area shows that paving/stabilization projects for 2011 eliminated only 216 miles of unpaved roads within the Phoenix PM10 nonattainment area, resulting in a reduction of PM10 emissions totaling 2,662 tons per year for 2011. The analysis for the Tonto National Forest is detailed in the final Air Quality report in the project record and summarized in chapter 3 of the final EIS. Also discussed, are the effects of designating varying amounts of motorized routes and areas on air quality in the analysis of all action alternatives (alternatives B, C, and D). The authorities responsible for implementation of the applicable SIPs Through compliance with the final Travel Management Rule, the Tonto 2504 for each Planning Area (Phoenix PM10, Miami PM10, Hayden PM10, National Forest has communicated and coordinated with the Arizona Payson PM10, Maricopa Ozone) should be contacted to ensure that Department of Environmental Quality. For more information, see the the proposed project conforms to the goals and requirements final Air Quality report in the project record and summarized in chapter contained in those SIPs. We recommend the FEIS include a more 3 of the final EIS. detailed discussion of how the project conforms to the guidelines of applicable SIPs and a description of the status of any consultation with the responsible agencies associated with those SIPs. Consult with the responsible planning agencies for specific Through compliance with the final Travel Management Rule, the Tonto 2504 recommendations regarding emissions calculation assumptions. Any National Forest has communicated and coordinated with the Arizona consultation should be described in the FEIS. Where this is infeasible Department of Environmental Quality. Tonto National Forest estimated or the planning agencies have no specific recommendations, the FEIS emissions for each criteria pollutant using the most recent and should more clearly discuss and support the assumptions made in the conservative data available. Otherwise, the assumptions made in the emissions inventory calculation. The most current available data calculation of the emissions estimates used in the for the air quality should be used where appropriate. analysis were adopted from the Maricopa Association of Governments

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Comment Letter Original Comment Text Forest Service Response Number (MAG) 2012 Five Percent Plan and the most recent emissions inventory containing PM10 emissions from off-road recreation vehicles, titled Revised 2011 Periodic Emission Inventory for PM-10 for the Maricopa County, Arizona, Nonattainment Area (PEI-2011) (MCAQD 2011). Based on the available data, emissions from the Tonto National Forest Travel Management Plan (TMP) either do not increase with respect to baseline emissions or are de minimis according to 40 CFR 93.153(b). This analysis and the assumptions associated with the analysis are detailed in the final Air Quality report in the project record and summarized in chapter 3 of the final EIS. The DEIS should have included a comprehensive analysis of Cumulative impacts were examined for all proposed alternatives and 2472 cumulative effects, including effects of the proposed actions along with reported in the final Air Quality report under the section titled all past, present and reasonably foreseeable future actions on the “Cumulative Effects of All Proposed Alternatives” as part of the air affected environment. (36 C.F.R. § 220.4(f) and 40 C.F.R. quality analysis. Past, present, and reasonably foreseeable actions §1508.7). The TNF must fully justify any incomplete or unavailable presented in the air quality analysis included: Recreational OHV use; information per the requirements of 40 C.F.R. § 1502.22. smoke from wildland and prescribed fires; wood burning; dust and pollution from urban development; dust from high winds and seasonal thunderstorm outflows; and emissions from motorized vehicle use. Fugitive dust emissions from unpaved roads, windblown dust, and industrial development are the primary contributors to poor air quality within the PM10 nonattainment areas. Outside of the PM10 nonattainment areas and in the higher elevations of the Forest, particulate emissions from smoke due to wood burning and prescribed and wildland fires are the primary culprits. Ozone precursor emissions from mobile sources, including OHVs, tend to be more problematic for the 8-hour Phoenix ozone nonattainment area. This analysis, including the cumulative effects analysis can be found in the final Air Quality report in the project record and summarized in chapter 3 of the final EIS. The cumulative impacts section should consider the extent to which Baseline and future emissions from Off-Highway Vehicles (OHV) use 2504 current and past OHV activity on the Forest affects air quality in the on the Forest were examined and their results reported in the final Air region. This section should also thoroughly discuss the anticipated Quality report in the project record, and summarized in chapter 3 of future trends in OHV use and the potential air quality impacts the final EIS. It identifies geographic areas within the Tonto National associated with continued growth in this form of recreation. Forest that are most sensitive to an increase in air pollutant emissions. Four class I wilderness areas were identified including the Pine Mountain Wilderness, Mazatzal Wilderness, Sierra Ancha Wilderness

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Comment Letter Original Comment Text Forest Service Response Number and the Superstition Wilderness. Five air quality planning areas were identified, including three 24-hour PM10 nonattainment areas, one 24- hour PM10 maintenance area and one area classified as nonattainment for ozone. Particulate, NOx and VOC emissions from OHV use were quantified for each sensitive area using baseline and future OHV activity levels. For any alternative where emissions increase, a corresponding decrease in air quality would be expected. Anticipated future trends are reported in the cumulative effect section of the Air Quality report. It states, in part, that “It is expected that present activities and their air emissions will persist in the reasonably foreseeable future.” Because the cross country OHV areas proposed under the preferred The effects of designating all motorized routes and OHV areas are 2504 alternative are concentrated in the southwestern area of the Forest, analyzed for their impacts to air quality in the Phoenix PM10 non- consideration should be given to whether they may impact air quality attainment area in the final Air Quality report in the project record, and in the Phoenix PM10 non-attainment area. summarized in the final EIS. Additionally, between the draft and final EIS, the OHV areas associated with Bartlett and Roosevelt lakes were decreased. This information can be found in chapter 2 of the final EIS. I do recommend soils data be factored into the modeling of emissions On site measurements of soil silt content were collected by the Tonto 2498 from motorized vehicles for each alternative. National Forest. These values were used in calculating emissions from unpaved publicly accessible roads per EPA AP-42 chapter 13.2.2 (equation 1b) and were used in the modeling for the effects analysis. This analysis can be found in the final Air Quality report in the project record.

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Climate Change Commen t Letter Original Comment Text Forest Service Response Number The Forest Service must use its existing data on motorized use of the As discussed in the “Climate Change” section of the final EIS, Agency 2472 Forest to quantitatively and qualitatively analyze the effects of a direction states, “it is not currently possible to ascertain the indirect motorized-route system on climate change, including estimates of effects of emissions from single or multiple sources”. The Forest is greenhouse gas emissions, as well as an analysis of the social cost of unable to predict differences in motorized vehicle use between the carbon as a result of that calculation. existing conditions and the various alternatives analyzed in the final Travel Management EIS. It is possible that a smaller motorized route system will result in reduced motorized vehicle use on the Forest. However, it is also possible that a similar number of users will be concentrated on a smaller network of motorized routes. Even if the number of motorized users on the Forest were reduced by an alternative that authorizes a smaller motorized route network, the displaced users may go to alternative locations off Forest and the net effect on greenhouse gas emissions would be unchanged. In the absence of this knowledge, it is not possible to compare differences in greenhouse gas emissions between alternatives. The Forest Service must quantify and describe the effects of the This has been completed, in detail, in the “Climate Change” section of 2472 proposed action on climate change, including use by motorized chapter 3 of the final EIS. vehicles on the designated route system. In the Climate Change section, analysis of the potential for motorized The Forest acknowledges that fossil-fuel based, motorized vehicle use 2498 travel to contribute carbon emissions to regional and global climate contributes to greenhouse gas emissions. However, as discussed in warming is inadequate. Alternative A has an associated level of carbon the “Climate Change” section of the final EIS, Agency direction states, emission from mobile sources that can and should be quantified. It “it is not currently possible to ascertain the indirect effects of emissions may be that the Alternatives B, C, and D do not increase carbon from single or multiple sources”. The Forest is unable to predict emissions, but they absolutely "authorize" the emission of whatever is differences in motorized vehicle use between the existing conditions produced, through the designation of routes and vehicular types. 8 I and the various alternatives analyzed in the final Travel Management recommend dropping this characterization, acknowledging that fossil- EIS. It is possible that a smaller motorized route system will result in fuel based, motorized recreation contributes to greenhouse gas reduced motorized vehicle use on the Forest. However, it is also emissions, and quantifying estimated emissions for each alternative. possible that a similar number of users will be concentrated on a That would better support the assertion that Alternatives B, C, and D smaller network of motorized routes. Even if the number of motorized are similar to current conditions. users on the Forest were reduced by an alternative that authorizes a smaller motorized route network, the displaced users may go to alternative locations off Forest and the net effect on greenhouse gas emissions would be unchanged. In the absence of this knowledge, it is

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Commen t Letter Original Comment Text Forest Service Response Number not possible to compare differences in greenhouse gas emissions between alternatives. In an effort to make a more convincing case on Climate Change The “Climate Change” section in the final EIS has been updated to 1 Effects on Future Air Quality Section/discussion beginning on 20 of 35, respond to comments. All applicable science was used in this analysis. recommend incorporating discussion, policy, criteria, on the USDA Forest Service Climate Change policy implementing on its projects. Some climate change USDA Forest Service includes USDA Forest Service Climate Change Resource Center, USDA Forest Service Climate Change website and a USDA Forest Service Climate Change Policy Considerations in Project Level NEPA Analysis (January 2009) pdf.file link at the following weblinks: http://www.fs.fed.us/ccrc/ http://www.fs.fed.us/climatechange/ http://www.fs.fed.us/emc/nepa/climate_change/includes/cc_nepa_guid ance.pdf http://www.fs.fed.us/climatechange/advisor/about-advisor.html http://a123.g.akamai.net/7/123/11558/abc123/forestservic.download.ak amai.com/11558/www/nepa/59232_FSPLT3_1653389.pdf

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Specific Routes Comment Letter Original Comment Text Forest Service Response Number FR114 - Mountain Meadow Drive The Alternative C Map depicts our Thank you for bringing this to our attention. The needed edits to the 11 private Mountain Meadow Drive as a passenger car compatible OPEN database have been completed and the private property in questions, forest road (FR114). If this is not corrected before the final decision, and the road accessing it, shows as private and not Forest Service new forest maps will be printed that depict OUR PRIVATE ROAD as land on the draft record of decision map. an open Forest Road. I believe if this happens we will see an increase in recreational visitors driving into our community looking for access to the creek and places to camp. By now you have received a number of letters pointing out the Thank you for bringing this to our attention. The needed edits to the 1714 problem of mislabeling FR 114 as open and suitable for all motor database have been completed and this route, and the private vehicles. As you will know, this is incorrect. property that it provides access to, shows as private and not Forest Service land on the draft record of decision map. Currently, there is an illegal route on the ground that is an extension of In this decision, we are not designating the unauthorized route the 2472 FR 303B. This illegal route is not shown on any of the DEIS maps. commenter mentions. We are fully aware that there are many This illegal route penetrates inside of the Picacho IRA. In previous unauthorized routes on the ground that will need to be rehabilitated as comments submitted in response to other TNF action, we detailed the funds become available. many NEPA violations that have occurred in this area. Attached is the location of a ATV track that enters the Sierra Ancha Thank you for the information. As shown in the draft record of decision, 21 Wilderness and at some point will need to be blocked and this route is not being designated for motor vehicle use and will not be decommissioned. on the motor vehicle use map. The action of rehabilitating or decommissioning the route on the ground will be conducted in future NEPA analysis. would like to have you consider the APS power line easement road Both Forest Service roads 284 and 1289 will be designated open to 1710 from our community easterly towards the Arizona Dept. of Transp. motor vehicle use. However, the existing route that the commenter Maintenance Yard and the roads that course towards the rim from describes as the "power line easement road" is not part of the existing that easement as well as the easement access roads from Highway system of routes and exists solely for Arizona Public Service to access 260. Also the APS power line easement from our community westerly their powerline as part of their existing easement. At this time, this towards Kohl's Ranch and the roads that course towards the rim from route will not be designated as a road or motorized trail open for public that easement as well as the easement access roads from Highway use. Allowing public use of this route will be considered in the future 260. Right now on FR284 and FR1289 are the only existing roads in when safe access off of highway 260 can be provided through a our immediate area that remain open for motorized travel. parking lot or staging area. I do have concern that in Alternate C there only two roads/trails Other motorized access, outside of Forest Service Roads 284 and 30 immediately adjacent to Christopher Creek that were identified as 1289 will be limited to Arizona Public Service to access their power being open to motorized vehicles: FR284 and 1289. line as part of their existing easement. In the draft record of decision,

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Comment Letter Original Comment Text Forest Service Response Number additional access will not be designated for public use. Allowing public use of this route will be considered in the future when safe access off of highway 260 can be provided through a parking lot or staging area. In the DEIS summary (pg. iv) it states, the modified proposed action, Utilization of roads identified as “administrative use only” is restricted 2405 Alternative C, would provide the most balance between protection of to Forest Service personnel and emergency response personnel. the natural and cultural resources, while still providing motorized Other authorized users of these routes can include special use and access to the public for a variety of recreational opportunities. As we grazing permittees; mining companies; county, state, and Federal stated earlier, there are legitimate reasons for keeping a road but agencies; private landowners; and utility companies. The consideration closing it administratively. However, for many existing roads that are for the amount of administrative use only routes being kept to a proposed to be closed administratively, if it is not for resource minimum fits within our process of designating these routes. In protection or any reason that is apparent to the AES. We cannot see a addition, the designation of administration use only was used to reason to close many of the roads and the AES is of the opinion that protect structures and improvements on the Forest, both Forest the public should have the right to use roads that have no identified Service managed and permittee constructed. resource impact. The proposed action to close most of the "administrative access only" roads to the public is totally "arbitrary and capricious" and would be illegal. As an example, let's examine closer two roads being administratively closed under Alternative C This document of yours shows that the Payson RD recommended the The draft record of decision does not designate the Monument Trail for 1716 Monument Trail be included as an authorized motorized trail. Please motor vehicle use. We believe that this route would better serve the see Map PRD 4.1: Payson RD ID Team Route Recommendations. recreating public as a non-motorized trail We have plans to work with This map appears on page 158 of the report which is page 17 4 of the the town of Payson to implement the final decision. 221 page .pdf file above. Alternative C looks okay except I would like to see FR 1828 kept open. Forest Service Road 1828 is designated administrative use only in the 2 This is part of the old Apache Trail (probably built around 1905 for the draft record of decision, with access to Salt River Project, to maintain dam construction). This road is used by people to reach the Tortilla their facilities. Additionally, this route is narrow and only allows for one Creek area (sometimes called Hells Hole) just southeast of the road. If vehicle to travel it at a time in either direction, which if open to the the road is closed, people will try to park on SR88, which will create public, could cause a safety hazard. safety problems. FR 1828 does not require any maintenance, it is not causing erosion, and will not require any monitoring by the Forest Service. Please keep FR1828 open. If alternative C is chosen, route 188 should remain open to all travel. Forest Service Road (FSR) 188 is a main road on the Pleasant Valley 5 This provides a unique highly technical route and there will have Ranger District and there is not intent of changing or discontinuing minimal environmental impact due to the limited usage of the route. motor vehicle access for the public. We are unsure either what section of FSR 188 the commenter is talking about or if they are referencing the correct route number. Each alternative has a spreadsheet of every route from the existing condition (including the unauthorized routes)

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Comment Letter Original Comment Text Forest Service Response Number and a detailed description of what it becomes for that alternative. This information can be found in the project record. The one issue we would like for the TNF to consider for inclusion into While the Tonto National Forest respects the commenter’s desire to 1712 Preferred Alternate C is this: FR 284 and FR 1289 are the ONLY have motor vehicle use on the Forest that meets their recreation existing roads in our Immediate area listed as remaining open in the needs, there are other considerations that the deciding official, the alternative. We feel this to be an inadequate estimation of the public's Forest Supervisor, must take into consideration as he designates recreational need. We would enjoy your consideration of the following motor vehicle use on the Tonto. Both Forest Service Road 284 and areas to remain open to motorized travel: 1. The Arizona Public 1289 will be designated open to motor vehicle use. However, the Service power line easement road from our community easterly existing route that the commenter describes as the "power line towards the Arizona Department of Transportation Maintenance Yard easement road" is not part of the existing system of routes and exists and the roads that course towards the rim from that easement as well solely for Arizona Public Service to access their powerline as part of as the easement access roads from Highway 260. 2. The Arizona their existing easement. At this time, this route will not be designated Public Service power line easement road from our community westerly as a road or motorized trail open for public use. Allowing public use of towards Kohl's Ranch and the roads that course towards the rim from this route will be considered in the future when safe access off of that easement as well as the easement access roads from Highway Highway 260 can be provided through a parking lot or staging area. 260. It is our belief that including these roads into Preferred Alternative C as open motorized trails will lessen the impact of high concentrations of recreating public on the two roads named in the alternative as well as provide for more reasonable opportunities for the public to recreate on these lands. I believe proposing that only these two roads be open for OHV The draft record of decision designates multiple motorized trails within 30 recreation near Christopher Creek is wholly inadequate to meet the the area the commenter is describing, providing for recreation use and public demand for motorized trails. access. Each alternative has a spreadsheet of every route from the existing condition (including the unauthorized routes) and a detailed description of what it becomes for that alternative. This information can be found in the project record. On TMP Alt C, a portion of Trail 939 is shown as closed, from the Forest Service Road (FSR) 939 where is continues south of FSR 1936 2482 intersection of Trail 1936 to Gun Creek, this should be left open as it is designated as a full-sized motorized trail to allow for public access to accesses the Fred pantry Cabin and Gun Creek in the Tonto Basin the cabin. Ranger District. At a minimum I recommend that the Forest consider adding the The existing route that the commenter describes as the "power line 30 following to the open motorized trail network. · Starting on the east, access road" is not part of the existing system of routes and exists there is a power line access road running northwest from FR 2654 solely for Arizona Public Service to access their powerline as part of near Sharp Creek to the Christopher Creek community. This road also their existing easement. In the draft record of decision, this route will has at least three service roads that run from Highway 260 to various not be designated as a road or motorized trail open for public use. points along the power line as well as two or three roads leading from Allowing public use of this route will be considered in the future when

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Comment Letter Original Comment Text Forest Service Response Number the power line north into the forest, presumably for past timber sale safe access off of Highway 260 can be provided through a parking lot activities. · Going to the west of Christopher Creek there is a or staging area. continuation of the same power line as mentioned above running westward from FR 284 to FR 657 and Highway 260. This power line access road also has several service roads that run from Highway 260 to various points along the power line. I believe that these road networks should be included as open The existing route that the commenter describes as the "power line 30 motorized trails within the Travel Management Plan. As the power line roads" is not part of the existing system of routes and exists solely for roads are adjacent to the Christopher Creek community, they offer Arizona Public Service to access their powerline as part of their additional high-clearance or seasonal opportunities for Off-Highway existing easement. In the draft record of decision, this route will not be Vehicle (OHV) enthusiasts. The demand and desire for OHV designated as a road or motorized trail open for public use. Allowing recreation opportunities in the Christopher Creek area is great and I public use of this route will be considered in the future when safe believe the Forest would be wise to offer as much connecting access off of Highway 260 can be provided through a parking lot or opportunities as is reasonably possible to fulfill this recreational staging area. demand. If another option instead of Dis selected, then modifications should be Comment lacks "supporting reasons for the responsible official to 1716 made to include additional authorized motorized trails. Specifically consider" per 36 CFR 218.2, along with site specificity to address in portions of the PATS trail system should be added . These are detail. However, the "PATS trail system" that the commenter refers to presently designated as motorized authorized. was considered at the district level when reviewing the designated motorized system for the Forest. Each alternative has a spreadsheet of every route from the existing condition (including the unauthorized routes) and a detailed description of what it becomes for that alternative. This information can be found in the project record. Vou should include the Monument Trail as a motorized trail. This trail The draft record of decision does not designate the Monument Trail for 1716 was recommended by the Payson RD to be Included in the authorized motor vehicle use. We believe that this route would better serve the motorized trails. recreating public as a non-motorized trail. We have plans to work with the town of Payson to implement the final decision. Even though the Payson RD recommended this be a motorized Each alternative has a spreadsheet of every route from the existing 1716 authorized route, the preferred plan C option does not include this condition (including the unauthorized routes) and a detailed description recommendation. Only option D includes this route. If you fail to adopt of what it becomes for that alternative. This information can be found option D, then whatever option is selected should be modified to in the project record. Alternative C was modified from the draft EIS in include this Monument Trail in the Payson RD recommendations. response to comments received. The draft record of decision does not designate the Monument Trail for motor vehicle use. We believe that this route would better serve the recreating public as a non-motorized

107 Travel Management on the Tonto National Forest

Comment Letter Original Comment Text Forest Service Response Number trail We have plans to work with the town of Payson to implement the final decision. Globe Ranger District. 1 The Oak Flat area needs to be set aside as a (1) Motorcycle trials is a cross-country motorcycle event that is 2314 motorcycle trials area, it also should be open for trials competition. 2 authorized on the Tonto National Forest through a special use permit FSR 580A is listed as admin, this creates two dead ends and should annually. Currently there is a 5-year permit authorizing 2 days per stay open to connect FSR 906 and 580. year for this activity. The Forest Service cannot set aside an open area for this use because of multiple resource concerns and uses such as hunting, tribal use, cultural resources, Arizona hedgehog cactus habitat, dispersed camping, and other recreation. The land exchange would result in the eventual loss of this area from Forest Service management. (2) Forest Service Road 580A is designated as administrative use only in the draft record of decision to protect electronic sites which are authorized by special use permit, and will not be open to public motor vehicle within the existing locked gates. Motorized access should not be permitted between the high and low In response to comments received, alternative C has been modified in 2471 water mark on Bartlett and Roosevelt Lake due to the potential for the final EIS. As detailed in the description of alternative C in the final negative impacts to riparian vegetation and threatened and EIS, chapter 2, the designated OHV area associated with Roosevelt endangered species habitat. and Bartlett lakes have been substantially modified to protect wildlife habitat while providing for recreational access. Additional information can be found in the project record located at the Supervisor's Office in Phoenix, Arizona. Neither of Trails U1048 or 1530B should be closed as they provide an In the draft record of decision, Forest Service Road 1530B is 2482 opportunity to camp in the cove and an opportunity to take out in designated for administrative use only as Salt River Project needs severe weather. access for maintenance. In addition, there is known endangered plant in the area and limiting motorized access will minimize the impacts to this species. U1048 is designated for decommissioning to protect the same resources. Since the lake is low approximately 95% of the year and there is ample access to other places to beach a craft before this location, neither of these routes will be open to public motor vehicle use. All the possible ways to cross the Verde River and make loop trips In the draft record of decision, Forest Service Road (FSR) 160 east of 2482 from Rio Verde over to Highway 87 have been closed. See the U2354 the river, which originates on the Mesa Ranger District, is designated area and the Trail 160 crossing at the Riverside Camp Ground. On the open to motor vehicle use up to the river. Approaching the river from original TMP Trail 160 river crossing was open part of the year to eastern side, there will continue to be signs indicating that there is no enable a loop trip to HWY 87. The river crossing for Trail 160 should river crossing and that there are seasonal motor vehicle use remain open seasonally, to keep the loop trip open to HWY 87. The restrictions for bald eagles where FSR 160 intersects with other. From

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Comment Letter Original Comment Text Forest Service Response Number Alternate C shows the crossing as administrative use only. What that the west, FSR 2150 and U2354 are designated open to public motor does is essentially turn the area on the east side of the river into a vehicle use up to the river, just east of Box Bar Ranch. At this time, the wilderness area, as it takes 7 hours to travel from HWY 87 to the crossing of the river is designated for administrative use only, to allow Verde River, via Trail 160. An alternative would be to establish the for Forest Service and other state and Federal agency access to fires U2354 area as a permit area, and allow access to Trail 160. The that frequently start on the eastern side of the river and timely fences and gates are already in place. In addition, the U2354 area is a emergency response to the area. Consideration of public motor vehicle wonderful place for families to picnic and camp by the river. As it is access for crossing the river through a permit system from October 1 now, the area is fenced off and people cannot access it, except by through November 30 will be addressed by the district ranger outside foot, which makes it very difficult for a family, with small children to of this analysis. access, as the area encompasses almost a mile of river. Keep Camp Creek Wash 413 open to River. Restrict access to river by In the draft record of decision, FSR 2150 and U2354 are designated 2482 fencing a corridor from 413 to new staging area above rest rooms on open to public motor vehicle use up to the river, just east of Box Bar FR 20. Look at Map 1 , connect U2214 wash/1110a with 1105 wash to Ranch. The crossing of the river is designated for administrative use form Loop. Connect 413 with wash 1106a for 50 inch OHV and under only, to allow for Forest Service and other state and Federal agency route. This will connect to the 1105 Jeep loop and to the 1111 route access to fires that frequently start on the eastern side of the river and that is also 50 inch designation. This allows for a bypass of your timely emergency response to the area. Consideration of public motor closed river routes and eagle nesting area and allow connection to the vehicle access for crossing the river through a permit system from FR 162 to head north to the FR 42 trails. Also spreads out access to October 1 through November 30, which is outside of the eagle closure two different river access points. Keeping the U2214 loop Open is a time period, will be addressed by the district ranger outside of this must. analysis. Keep all trails that access Roosevelt and Horseshoe Lakes open. In the draft record of decision, there are multiple designated motorized 2482 People like to camp and picnic next to the water. These are not trails within the area the commenter is describing, providing for wilderness lakes, as they both allow motor boats. recreation use and access. U.S. Forest Service routes should not dead end into STL. This implies Public lands are intermingled with State Trust lands throughout the 2496 that the Forest Service route continues through STL. Following are the planning area, presenting potential issues related to public use and U.S. Forest Service route numbers that fall into this category: Route travel management. State Trust lands are available for public 3169: Motorized Trails (T9N, R3E, Section 33) Route 46: Motorized recreational use with a permit issued by the Arizona State Land Trails (T8N, R3E, Section 4 and Section 16). Route 41: High Department (ASLD) according to State regulations. The existing roads Clearance Vehicles (T7N, R3 E, Section 9). Table Mesa Road, east of and trails across State Trust lands are used and maintained by land I-17, is a major access route to the Tonto National Forest. There is no use authorization holders (county, mining, grazing, utilities, etc.), and public use right-of­way on this road as it crosses STL. It needs to be are not subject to Forest Service travel management designations legalized across all sections where it crosses STL. Routes 101 & I08: unless provided for under a right of way or other form of written Non-motorized Trails (T l N R9E Section 27) Route 108 Non- authorization from ASLD. Several existing routes important for the motorized Trail (TIN RlOE Sections 25 & 26) Routes 3494, 3495 & Tonto National Forest transportation system are identified for pursuing 3711 Administrative Use & Motorized Trails (TIS R il E Sections 7, 31) rights of way or other authorization for roads and trails essential for the Routes 497, 3197 & 53: Motorized Trails (T7N, R3E, Section 21 & 33). use and administration of public lands, to provide legal public access

109 Travel Management on the Tonto National Forest

Comment Letter Original Comment Text Forest Service Response Number This road, which connects to New River Road, does not have a right- and maintain them for their intended purpose. When motor vehicle use of-way and should be legalized where it crosses STL through T7N, maps are generated in compliance with the final Travel Management R3E, Section 20. Trust land adjacent to Section 33 is under a mineral Rule, we anticipate including language, similar to that being used by exploration lease. Mineral leaseholders purchase the exclusive rights, the BLM that will indicate that travel routes depicted on maps across including access, for land under the permitted lease. Routes 31 5, Arizona State Trust Lands, other Federal lands, or private lands do not U315A, U315B, 3153, 2466, 2469, 2472, and 3139: High Clearance imply legal public access to use or cross those lands. Any public use Vehicles, Motorized Trails & Administrative Use (TIS, Rl3E Sections 3, of State Trust Lands is strictly under the jurisdiction of the Arizona 4, 5, 17 & 21). Trust land in these sections is currently under m ineral State Land Department; use of other Federal lands is subject to their exploration permits and may be converted to full Mineral leases in regulations; and use of private lands requires permission of the conjunction with the development of the Resolution Copper project. landowner. All users much comply with State policies and regulations, Mineral leaseholders purchase the exclusive rights, including access, other Federal land management agency regulations, and private for land under the permitted lease. The U.S. Forest Service should landowner rights in order to legally use or traverse lands outside of the evaluate the need for access across STL in this area and purchase Tonto National Forest. appropriate rights-of-way or reconfigure their TMP to be contained within the Tonto National Forest boundaries Routes 2548, 248, 2528, 2521, and 2691: High Clearance Vehicles, Motorized Trails, (TIS, R14E Sections 7, 18, 22 & 23). Routes 228, 221, 112, and 2676: High Clearance Vehicles, Motorized Trails, Administrative use (TIS, R I SE Sections 19, 20 & 21). Route 553: Administrative use: (T I N R I SE Section 5). Trust land in this section is under a mineral exploration lease. Mineral leaseholders purchase the exclusive rights, including access, for land under the permitted lease. Preventing motorized use on the Payson Area Trail System which All of the trails identified by the commenter will be designated for motor 2500 includes the Houston Loop Trail that was specifically designed for use vehicle use. Specifically, Houston Loop Trail has been designated by the Houston Equestrian Horse camp, Monument Peak Trail, motorized to allow access to the rest of the trails (Monument, Boulders Trail (north and south), Cypress Trail, Peach Orchard Trail Boulders, and Cypress). Peach Orchard Trail provides for motorized and Loop, Round Valley Trail, and American Gulch Trail. trail opportunity that connects to Main Street in the town of Payson. Round Valley Trail provides for motorized loop recreation, and American Gulch Trail provides access to hunting, recreation, and natural resource survey opportunities. Maintain 1260a and 1260 as motorized travel, (known as outlaw trail) In the draft record of decision, Routes 1260A and 1260 are designated 2500 this is a very wide road used by residents of Round valley and OHV for motor vehicle use to provide for recreation opportunities. riders. Eliminate 5004 (shortcut off of Nf 1260 to Nf 412, not cost effective to We believe that the commenter is referring to route S004, which has 2500 maintain). been designated to be decommissioned in the draft record of decision

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Comment Letter Original Comment Text Forest Service Response Number as it is redundant and not needed to provide for recreation opportunities. Round Valley Loop is part of Payson Area Trail System that should be Comment is an opinion and lacks "supporting reasons for the 2500 non-motorized. Round Valley area north of Nf 412 has major erosion responsible official to consider" per 36 CFR 218.2. Prior to signing the causing major flooding due to excessive cross country use. Full size record of decision implementing the final Travel Management Rule, trucks and OHV are causing major damage and destruction to the much of Payson was open to cross-country travel by everyone. Once environment and major washing into creek and river beds that effect signed, this will no longer be the case and much of the commenter's residents. These specific trails are in close proximity to our homes and concerns will be addressed. In addition, the Round Valley Trail will be communities. If motorized use is allowed it will effect the VALUES of maintained as outlined in the draft implementation strategy, which can our home, safety for our families, safety against fire, vandalism. Will be found at http://data.ecosystem-management.org/nepaweb/fs-usda- increase noise pollution, air pollution, protect our environment, pop.php?project=28967 or in the project record at the Supervisor's erosion, water sheds, wells, wild life habitat, beauty of our Office in Phoenix, Arizona. Furthermore, with the decommissioning of communities and the quality of life we all enjoy); S004 we believe that much of the erosion that the commenter is referring to will be addressed. would like to have you consider the APS power line easement road Both Forest Service Road 284 and 1289 will be designated open to 1710 from our community easterly towards the Arizona Dept. of Transp. motor vehicle use. However, the existing route that the commenter Maintenance Yard and the roads that course towards the rim from describes as the "power line easement road" is not part of the existing that easement as well as the the easement access roads from system of routes and exists solely for Arizona Public Service to access Highway 260. Also the APS power line easement from our community their powerline as part of their existing easement. At this time, this westerly towards Kohl's Ranch and the roads that course towards the route will not be designated as a road or motorized trail open for public rim from that easement as well as the easement access roads from use. Allowing public use of this route will be considered in the future Highway 260. Right now on FR284 and FR1289 are the only existing when safe access off of highway 260 can be provided through a roads in our immediate area that remain open for motorized travel. parking lot or staging area. Further east between Hells Gate Canyon and Moore drainage is Adjacent Forest Service Roods 144 and 31 provide access to the area 2405 FS1221 which is open for only a short distance north of the Control that the commenter is referring to and are better maintained. As such, Road and then administratively closed under Alternative C and left as Forest Service Road 1221 will be open only to administrative use, and a ML2 road under Alternative D. Again there is minimal resource will access, in part, range improvements. The draft record of decision damage because it is along a ridge top out of the drainage. There is took into account route densities for the area and effects associated no reason that this road should be administratively closed other than with where 1221 crossed the stream in order to minimize impacts to perhaps the assumption that one mile is a reasonable distance to resources according to the minimization criteria identified in 36 CFR walk. This may be a reasonable assumption on flat ground but when 212.55(b). Utilization of roads identified as “administrative use only” is there are canyons that are between you and the next road the AES restricted to Forest Service personnel and emergency response disagrees with this assumption and disagrees with closing hundreds of personnel. Other authorized users of these routes can include special miles of existing roads to the public but keeping them open for use and grazing permittees; mining companies; county, state, and administrative use when they are existing roads which are not doing Federal agencies; private landowners; and utility companies. The excessive resource damage and the AES feels that the public has the consideration for the amount of administrative use only routes being

111 Travel Management on the Tonto National Forest

Comment Letter Original Comment Text Forest Service Response Number right to use them. To do otherwise only alienates the very public that is kept to a minimum fits within our process of designating these routes. served by the FS and the FS acknowledges that to enforce a closure In addition, the designation of administration use only was used to of these existing roads would be very difficult. We do not have the protect structures and improvements on the Forest, both Forest resources nor the time to go over the entire Forest road by road to Service-managed and permittee-constructed. identify all roads like the example we provided but would be willing to provide volunteer help to do so based on the line officer decision. The AES is questioning why under Alternative C, FS 1212 and 1221 Forest Service Road 1221 will be open only to administrative use, and 2405 are administratively closed and would recommend that they (plus all will access, in part, range improvements. The draft record of decision others not leading to excessive resource damage) be designated as took into account route densities for the area and effects associated motorized trails. with where 1221 crossed the stream in order to minimize impacts to resources. Forest Service Road 1212 will also be open only to administrative use to allow for the management of timber and prescribed fire in order to minimize the impacts of the road on watershed conditions. To the west is FS1210 which is a ML2 providing access to the private In the draft record of decision, Forest Service Road 1212 is designated 2405 land that makes up Bonita Estates. Access has been restricted by the for administrative use only to allow for the protection of breeding private land preventing travel north of the private land so it makes populations of brook trout. Because of this, only FSR 1213 will permit sense that FS1210 be decommissioned north of the private land. motor vehicle users access into that general vicinity. However, this also is a very good reason why FS1212 (the road immediately to the east) should be open to provide access to the area up above Bonita Estates that is between Bonita and Perley Drainages. The road accesses a FS wildlife guzzler (Upper Perley) and does little resource damage because the road is entirely on a ridge top not being close to the drainage bottom. I am concerned that the proposed plan appears to make permanent In the draft record of decision, Forest Service Road 22 is designated 2514 the "temporary" closure of the FS 22 to Bushnell Tanks and Reno for administrative use only to allow for necessary permitted uses by Pass. First, I note that the closure of this road has always been other agencies, such as the Arizona Game and Fish Department and described by the FS to be a temporary measure for safety purposes, U.S. Geological Services, and ranch maintenance by the permittee, while at the same time ranchers and other permittee have been while continuing to protect resources impacted by the fire. All roads allowed to use these roads even though the roads are allegedly that intersect with this road will also be designated for administrative unsafe. use only, unless designated for decommissioning. Utilization of roads identified as “administrative use only” is restricted to Forest Service personnel and emergency response personnel. Other authorized users of these routes can include special use and grazing permittees; mining companies; county, state, and Federal agencies; private landowners; and utility companies. The consideration for the amount of

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Comment Letter Original Comment Text Forest Service Response Number administrative use only routes being kept to a minimum fits within our process of designating these routes. In addition, the designation of administration use only was used to protect structures and improvements on the Forest, both Forest Service-managed and permittee-constructed. Road 2814 is the access to one of the most idyllic 4WD campsites I As detailed in the description of alternative C and in the draft record of 2482 have ever found in my 50 years of camping, and it is shown as decision, the Cherry Creek Road (Forest Service Road 203) has been administrative use only. The trail needs to be opened so people can designated as decommissioned and after site-specific analysis, will be enjoy camping by Cherry Creek. The trail leads to a large sandy bench blocked from motor vehicle travel south of where it first enters the adjacent to Cherry Creek, where many campers can camp close to Sierra Ancha Wilderness from the north, south of P.B. Creek and Cherry Creek. where it exits the wilderness area near Devils Chasm. Any existing routes that originate from FSR 203 between these points, like FSR 2814, are also designated for decommissioning as there will be no way to access them. In Insert 4, route 2097A should remain open to full motorized travel. In the draft record of decision, Forest Service Road 2097A is 5 This route allows connection between route 2097C and 413. This designated as a motorized trail to provide for trail connectivity as the route appears to have reached a stable state, and keeping it open will commenter requests. result in minimal impact. Closing the route would have a larger impact as it will result in users turning around and retracing their travel on route 2097C. Turning around may have an impact as it will result in travelers unintentionally driving on undisturbed soil. In addition, route 2097A provides a unique technical experience in the availability to travel in a steep and off-camber route. In Insert 4, route 2117 where it connects to the paved Needle Rock In the draft record of decision, Forest Service Road 2117 is designated 5 road (Route 20?), the short rocky climb on the south side should as a motorized trail that is open to full-sized vehicle and other OHVs. remain open to all vehicles. This route provides an ability to perform some rock crawling and have minimal environmental impact as it is all solid rock. In Insert 3, I'm assuming that all routed in the "Sycamore Creek Open As defined in the final Travel Management Rule, an area is a “discrete, 5 Area" are shown as red (closed) because the entire area is open to all specifically delineated space that is smaller, and in most cases much vehicles. If this is correct, I have no comment on this area. If this is smaller, than a Ranger District” (36 CFR 212.1). In designating an incorrect, routes for full-size vehicles need to be added and analyzed area for motor vehicle use, specific routes within a designated area are in order to allow connection to other established routes, such as 1849 not necessary as motor vehicle use is permitted within the entire area and 1841. unless otherwise prohibited. Routes within an area may be shown on

113 Travel Management on the Tonto National Forest

Comment Letter Original Comment Text Forest Service Response Number the motor vehicle use map if it shows connectivity of routes that enter and exit an area. As I review this proposal it becomes readily obvious it is a complete Forest Service roads (FSR) 605, 3157, 557, 587, 595, 610, 611, 1981, 554 disaster for Forest visitors. Working as a volunteer in the Northwest 585, and 3195 are designated as motorized trails, open for public use. section of the Cave Creek Ranger District, I am seeing the proposed FSR 481 will be designated as a road and remain open to public use. elimination of the following routes: FR 605 FR 3157 FR 557 FR 587 FSR 391 is designated for decommissioning to minimize effects to FR 595 FR 391 FR 610 FR 611 FR 1981 FR 585 FR 3159 FR 481 wildlife and the road is currently in poor condition and is likely causing south of the Rosalie Mine Closure of part of FR 36 to the Copper resource damage. FSR 36 is designated for administrative access only Creek Guard Station, a NHR site. Technically many of these roads for the fire base of operation; however, the public is still able to walk to would be decommissioned to Motorized Trail status which would then the historic site. Routes designated as general motorized trails will be strictly limit their use to hunters only. It would also deny access to open to full-sized vehicles and in many instances access on them will many historic and Native sights. Effectively, unless a Forest visitor is a not change from what is currently available. Nothing about hunter, most of the area would become roadless under this plan designating a route as a general motorized trail limits it to hunter access only. Forest Roads 610 and 611 access the Agua Fria National Monument Forest Service roads (FSR) 605, 557, 610, 611, 1981, 585, and 3195 554 and significant cultural sites there. Forest Road 1981 accesses Turret are designated as motorized trails, open for public use. FSR 481 will Peak, the location of which has been dropped from your current official be designated as a road and remain open to public use. FSR 399 is Forest map. Forest Road 481 accesses Brooklyn Peak and is in need designated for decommissioning as it does not provide necessary of repair South of the Rosalie Mine but it is viable (The route suffered access in the area. heavy damage after the Cave Creek Fire). Other numerous roads including FR 605, 557, 585, 3159, 399 are all used by Ranchers and Fish & Game personnel. I was recently asked by Fish & Game if I had plans to debrush FR 605. The initial answer was "yes" however this proposed plan leaves that in doubt. This section of the Tonto does not see a lot of visitors or abuse by those who do travel through the area. Most of the roads that suffered significant damage from erosion after the Cave Creek fire have been repaired by the Forest Service. Only a few still need some reworking. Forest Road 1828 which is a short distance east of Tortilla Flat off the Forest Service Road 1828 is designated administrative use only, with 1441 Apache Trial. This road is historic as part of the old Apache Trail access to Salt River Project, to prevent damage to their facilities. alignment or the Mesa-Roosevelt Road as it was known around 1905. Additionally, this route is narrow and only allows for one vehicle to FR 1828 is used quite a bit by people wanting to hike into the Tortilla travel it at a time in either direction, which if open to the public, could Creek area. Parking at Tortilla Flat is on private property at the cause a safety hazard. owner's discretion and parking on turn-outs along the Apache Trail can be dangerous. Forest Road 1828 is well traveled and does not require maintenance, plus it is not causing erosion. It affords a safe

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Comment Letter Original Comment Text Forest Service Response Number place to park while exploring the old road and for hiking in this part of the Superstition Wilderness. Please consider keeping FR1828 open. The other road I submit to remain open is located off FR252 and just The route we believe the commenter is addressing is U3451A, an 1441 west of FR3451, it does not have a road number. This short well unauthorized route, which is designated for decommissioning as there traveled road leads to a safe camping area that is out of the Robles are several camping opportunities in the area that can be accessed Canyon drainage. Closing this road will cause people to go cross from designated motor vehicle trail 3451 and Forest Service Road 172. country into washes to camp. I ask that you keep it open for easy While motorized access to the commenter's camping spot could be access to a safe camping area. limited by decommissioning this route, camping in this spot is still permitted, just possibly not accessible via a motor vehicle. Once a motorized system has been designated and a motor vehicle use map has been published, driving off of a designated route is not permitted per the final Travel Management Rule. Please add the highlighted routes that have numbers on the attached Forest Service roads (FSR) 1644, 1643, the part of 1641 north of 1712 topo map I provided be open to the public (1307, 1308, 1309, 1310, where it intersects 1640 are designated for decommissioning to 1311, 1640, 1641, 1642, 1643, 1644, 2654) decrease route density in the area and to minimize effects to resources per 36 CFR 212.55(b). The rest of the routes identified by the commenter are open to the public for motor vehicle use. Additionally, each alternative has a spreadsheet of every route from the existing condition (including the unauthorized routes) and a detailed description of what it becomes for that alternative. This information can be found in the project record. Pleasant Valley District: 1. FSR 767 dead ends. If FSR 767A was left (1) Forest Service Road (FSR) 767A is designated for 2314 open this would allow a looped road, it is about 1 mile long. This would decommissioning as based on areal imagery and site-specific connect FSR 489 and 609. 2. FSR 291B and 173 should be left open knowledge this route does not currently provide for a connection to create a loop between FSR 291A and 772. It is maybe a mile long. without necessary route construction. (2) FSRs 291B and 773 are 3. FSR 964 should be open, less than a mile long to create a loop designated for decommissioning due to poor recreation opportunities between FSR 485 and 932. 4. FSR 795 is now closed and should be and to minimize the impacts to watershed resources. (3) FSR 964 is open as it would create a nice loop between FSR 486 and 609. 5 PV designated for decommissioning to decrease the road densities in the 4008 west of Young is closed and creates a dead end on PV 4009 area and it provides unnecessary access. (4) FSR 795 is designated instead of a loop to FSR 129. 6. Leave FSR 2994 open to join FSR for decommissioning as based on areal imagery and site-specific 854A and 187 in a loop. This will also keep people from crossing knowledge this route does not currently provide for a connection private property on FSR 854. 7 PV 4070 should stay open, it is only without necessary route construction. (5) FSR 4008 is designated as a 1/4 mile long and creates a loop between FSR 123 and 856 which has motorized trail to address the need to create recreational loop a neat water tank at the end. 8 Leaving FSR 638-640 and 859 open opportunities and to decrease the number of “dead-end” routes on the creates a very nice loop and bypasses a boring riding section on FSR Forest that are not needed for access to known dispersed camping 609. 9 PV 3036 and PV 3038 should be left open to create a great sites or other recreation opportunities. (6) FSR 2994 is designated for

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Comment Letter Original Comment Text Forest Service Response Number loop that goes back and connects to PV 3010, Nice trail as it is hard to decommissioning as it has been “nature reclaimed” and does not exist find, you have to go into an old corral to find the start. 10 FSR 2934 on the ground after the water tank. (7) FSR 4070 is designated for which is maybe a 1/2 mile long should be left open to loop FSR 411d decommissioning due to road density concerns and the current poor and 291A. quality of road. (8) FSRs 638, 639, 640, 859 are designated for decommissioning due to damage from the Mistake Peak Fire and to minimize impacts to watershed resources. (9) FSR 3038 is designated open to motor vehicle access as it provides access to the existing water tank for the permittee, while also providing recreational loop opportunities, while 3036 is designated for decommissioning due to road density concerns in the area, which can impact wildlife and water resources. (10) FSR 2934 is designated for decommissioning to minimize impacts to the stream where the road crosses it. Mesa Ranger District. 1. I see that FSR 22-23 and 524A Bushnell (1) Forest Service Road (FSR) 22 is designated for administrative use 2314 Tank are listed as Administrative Use Roads. I understand the issue only to allow for necessary permitted uses by other agencies, such as with the gate and liability concerns due to flooding and also that there the Arizona Game and Fish Department and U.S. Geological Services, was a fire in the area a while back. The area is now overrun on and ranch maintenance by the permittee, while continuing to protect weekends with mountain bikes setting them over the gate. If liability is resources impacted by the fire. (2) Route P6012 is designated for the issue what is the difference between mountain bikes, motorcycles decommissioning as single-track opportunities are offered in other or jeeps, bad choices could lead to bad things. If nothing else these areas on the Forest, specifically on the Cave Creek Ranger District. roads should be open and access granted from the Roosevelt side, Additionally, there is a need to prevent illegal route proliferation north once the area can opened up from fire damage. 2. The Dagger of FSR 3456. 3. FSR 1089, which is on the Cave Creek Ranger motorcycle trail P6012 is closed. This a very tough trail that only better District, is designated as a motor vehicle trail. The adjacent route is an riders can ride. It gets very little use and there would be very little if unauthorized route that is designated for decommissioning as it is any impact if it was left open. 3. Is FSR 1089 open or closed at redundant to FSR 1089. (4) From where Forest Service Road (FSR) Sycamore, the map shows it as red and blue so I cannot tell, it should 393 originates south west of Bartlett Lake to where it intersects with stay open to make a loop. 4. I hope I am wrong but in the preferred FSR 3456, this portion will be designated for administrative use only— plan it looks LIKE FSR 393 which cuts across .60 miles of the SE in part to allow Arizona Public Service (APS) to service their Four corner of the Matazel wilderness is going to become an admin road. Corners to Pinnacle Peak 345kV Power Transmission Line—and not This road is very popular with jeep, atv and long distance motorcycle open for public motor vehicle use. From the intersection with FSR riders. This would create 2 dead ends and force people to come in 3456 until it encounters the southeastern boundary of the Mazatzal from Sunflower or Bartlett Lake only, very bad idea. ( Draft special Wilderness boundary, FSR 393 is designated as a motorized trail. For areas page 39) I hope a bypass is planned. The power line and road the 0.62 miles that 393 is within the Mazatzal Wildness boundary, FSR pre dates the wilderness so I doubt the wilderness boundary shown on 393 is designated administrative use only in compliance with the the map is correct. special use permit issued to APS in 2012. Where FSR 393 exits the wilderness boundary near the northwest corner of section 2 until it intersection with FSR 627, it is designated as a motorized trail. Both the Wilderness Act of 1964 (P.L. 88-577) and the Arizona Wilderness

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Comment Letter Original Comment Text Forest Service Response Number Act of 1984 (P.L. 98-406) allow for this type of non-conforming use within the wilderness. In 1961, the Tonto National Forest authorized APS, via a special use permit, to maintain the Four Corners to Pinnacle Peak 345kV Power Transmission Line. As part of the special use permit, APS was authorized motor vehicle access to maintain this transmission line. One such route named in the original permit is Forest Service Road (FSR) 393, which originates near the Verde River southwest of Bartlett Lake and follows the transmission line northwesterly until FSR 393 connects with FSR 627 south of Cross Ranch—FSR 627 was originally State Highway 87 before it was realigned by the Arizona Department of Transportation. With passage of the Wilderness Act in 1964, the legal boundary for the Mazatzal Wilderness was drawn incorporating sections of both FSR 393 and part of the transmission line within the boundary—the maps used for the legal mapping where early 1950s quadrangle maps. A legal description with maps, prepared in 1970 that superseded the previous legal description, still showed both a portion of FSR 393 and the transmission line within the wilderness boundary. With the passage of the Arizona Wilderness Act of 1984, an updated legal description and maps were produced, superseding previous legal descriptions. In this version, the eastern boundary where is connects with the southern boundary was moved and the transmission lines where no longer within the designated wilderness boundary; however, the road continues to be within the wilderness boundary. Cave Creek Ranger District. 1. FSR 18B should stay open, it is a (1) Forest Service Road (FSR) 18B is designated for decommissioning 2314 challenging jeep road that does not get much use due to difficulty. If as it is located in a perineal creek, which is one of the few cold water there is an issue with vehicles near the Verde then close the last 1/4 creeks on the Tonto National Forest. Excluding motor vehicle use on mile. Since eagles were removed from the T and E listing that also this road will minimize effects to sensitive habitat for threatened and should not be an issue. I would support this road having to have endangered species. Additionally, the route is in such bad condition, it permit to travel on it. 2. Leave P4048 P4048A P4049 P5014C 1089 is nearly impossible for emergency vehicle to access it. (2) The route 1096C and D open to create an expert level motorcycle trail that can that consists of FSRs P4048, P4048A, P4049, P5014C, 1089, 1096C, only be ridden by the best riders in the best shape. With so little usage and 1096D is designated for decommissioning to decrease OHV there will be no resource issues. Could be adopted by a motorcycle trespass on adjacent Tribal lands. Additionally, the route is so club. 3. U2126 should be open to create a loop for motorcycles out of technical and rough that law enforcement would be unable to respond Campcreek Wash after riders visit the water fall, in and back out is not to calls about use and to verify that it is not contributing to resource as fun as a loop. 4. Leave 1086 and 1087a open, I rode these trails for damage. (3) U2126 is designated for decommissioning because it is in a sensitive watershed and is on loose, easily eroded soils which could

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Comment Letter Original Comment Text Forest Service Response Number many years before the fire, this a high use OHV area and many bikes impact a major drainage. In order to minimize these effects, this route are street legal so a loop onto Horseshoe dan RD is not a problem. will be decommissioned. (4) FSR 1086 and 1087A are designated for decommissioning because they are within the permit zone and in order to control access, there needs to be limited access off of FSR 205. Tonto Basin Ranger District. 1 . FSR 1502 should stay open, about a (1) Forest Service Road 1502 is designated for decommissioning as 2314 mile long to connect FSR 189 to 489 and create another loop instead the northern end has been naturally decommissioned for a few years of a dead end. Just because it is close to the Sierra Ancha Wilderness due to a steep talus slope. The south end goes in about 0.75 mile and boundary is not a good reason to close this road and create two dead then has naturally decommissioned itself. There is no access for the end roads. 2 U344A is a road I went on years ago when SR188 was permittee or for special uses, thus there are no use needs. (2) FSR 26 still dirt, it needs to stay open to access a nice camping area and join is designated administrative use only and will not be open to motor up with FSR 26 vehicle use, thus all routes that originate from it will also not be designated for motor vehicle use. U344A is designated for decommissioning. We would like to thank Tonto National Forest for recognizing the fact Forest Service Road 569 is designated for administrative use only to 2472 that the Verde River Sheep Bridge is intended for non-motorized use protect the existing utility company gaging station and other facilities in both Alternative C and B. We are both curious and somewhat that have been vandalized in the past. amazed that Alternative B shows FR 569 as being recommended for decommissioning. We do not support this classification as FR 569 is actually a well-used road from start to finish. However, there is a need to construct better physical barriers at the west end of the Verde River Sheep Bridge along FR 569. The Verde River Trail # 11 actually starts at the west end of the Verde Road 3183 is another road I have seen that I want to go on that a Forest Service Road 3183 is designated as a general motorized trail to 2482 portion of it is being closed. This road will provide many opportunities provide access for recreational opportunities. to camp on a ridge, where a person can sit and watch for game. Road # 18B, Red Creek should not be administrative use only. This Forest Service Road (FSR) 18B is designated for decommissioning as 2482 trail provides a unique access point to the Verde River. It is the only it is located in a perineal creek, which is one of the few cold water road that provides a remote access to a riparian area where a family creeks on the Tonto National Forest. Excluding motor vehicle use on could camp by the river with a vehicle. All other areas are closer to this road will minimize effects to sensitive habitat for threatened and Phoenix and normally crowded. The trail accesses the river at the end endangered species. Additionally, the route is in such bad condition, it of the boundary of the wild and scenic river. Also, the Mazatzal is nearly impossible for emergency vehicle to access it. Wilderness Area is shaped to allow motorized access to the river. This is also an important access for river runners, as it is the only place in many miles that a person could take out, if conditions became too sever for them, where they could retrieve their equipment with a vehicle. If the thought is to create more wilderness area there, it does

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Comment Letter Original Comment Text Forest Service Response Number not qualify, as there is an old airstrip there. As an alternative this trail could be permitted like Bull Dog Canyon. Road # 568 should not be closed. It provides close vehicle access to a In the draft record of decision, Forest Service Road 568 is designated 2482 beautiful little cove and beach on the Verde River that a family could as a motor vehicle trail and is open to public access to provide for access with small children. It is less than a 20 minute hike down a recreational opportunities. gentle wash to the river. If the road is closed, the hike will be more than three miles, which will be prohibitive for many on a hot summer day, especially families with children. In addition this trail is the way out if you do a through hike down the East Fork of the Verde River. Road 1897 should not be closed as it provides an opportunity to camp Forest Service Road 1897 is designated as a motorized trail as it 2482 beside the Verde River, which are very few and far between. provides for a unique recreational opportunity. For Route 77 (Tl N, R I OE, Section 29), Pinal County needs to perfect Public lands are intermingled with county lands throughout the 2496 the legal access across Peralta Road in order for the public to access planning area, presenting potential issues related to public use and the Peralta trailhead. travel management. Routes outside of Forest Service System roads are not subject to Forest Service travel management designations unless provided for under a right of way or other form of written authorization. Several existing routes important for the Tonto National Forest transportation system are identified for pursuing rights-of-way or other authorization for roads and trails essential for the use and administration of public lands, to provide legal public access and maintain them for their intended purpose. When motor vehicle use maps are generated in compliance with the final Travel Management Rule, we anticipate including language, similar to that being used by the BLM that will indicate that travel routes depicted on maps across county lands, other Federal lands, or private lands do not imply legal public access to use or cross those lands. Any public use of county lands is strictly under the jurisdiction of the county; us of other Federal lands is subject to their regulations; and use of private lands requires permission of the landowner. All users much comply with county policies and regulations, other Federal land management agency regulations, and private landowner rights in order to legally use or traverse lands outside of the Tonto National Forest. .Route# 393 (Powerline road at south end of Matzatzal, 0.64 miles of From where Forest Service Road (FSR) 393 originates south west of 2497 road in wilderness)-proposed to be "Administrative Use Only" in Bartlett Lake to where it intersects with FSR 3456, this portion will be Alternative Con Page 128 of the DEIS. This would be a significant loss designated for administrative use only—in part to allow Arizona Public Service (APS) to service their Four Corners to Pinnacle Peak 345kV

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Comment Letter Original Comment Text Forest Service Response Number of access for the recreating public to a large area east of Bartlett Lake. Power Transmission Line—and not open for public motor vehicle use. The Department requests that route # 393 remain open. From the intersection with FSR 3456 until it encounters the southeastern boundary of the Mazatzal Wilderness boundary, FSR 393 is designated as a motorized trail. For the 0.62 miles that 393 is within the Mazatzal Wilderness boundary, FSR 393 is designated administrative use only in compliance with the special use permit issued to APS in 2012. Where FSR 393 exits the wilderness boundary near the northwest corner of section 2 until it intersection with FSR 627, it is designated as a motorized trail. Both the Wilderness Act of 1964 (P.L. 88-577) and the Arizona Wilderness Act of 1984 (P.L. 98- 406) allow for this type of non-conforming use within the wilderness. In 1961, the Tonto National Forest authorized APS, via a special use permit, to maintain the Four Corners to Pinnacle Peak 345kV Power Transmission Line. As part of the special use permit, APS was authorized motor vehicle access to maintain this transmission line. One such route named in the original permit is Forest Service Road (FSR) 393, which originates near the Verde River southwest of Bartlett Lake and follows the transmission line northwesterly until FSR 393 connects with FSR 627 south of Cross Ranch—FSR 627 was originally State Highway 87 before it was realigned by the Arizona Department of Transportation. With passage of the Wilderness Act in 1964, the legal boundary for the Mazatzal Wilderness was drawn incorporating sections of both FSR 393 and part of the transmission line within the boundary—the maps used for the legal mapping where early 1950s quadrangle maps. A legal description with maps, prepared in 1970 that superseded the previous legal description, still showed both a portion of FSR 393 and the transmission line within the wilderness boundary. With the passage of the Arizona Wilderness Act of 1984, an updated legal description and maps were produced, superseding previous legal descriptions. In this version, the eastern boundary where is connects with the southern boundary was moved and the transmission lines where no longer within the designated wilderness boundary; however, the road continues to be within the wilderness boundary. We support Alt C with changes proposed by AZOHVC and TRAL in In the draft record of decision, Forest Service Road 42 that the 2506 their separate letters of comment with only one exception noted below commenter is referencing is designated as a motorized trail open to related to FR42. public access.

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Comment Letter Original Comment Text Forest Service Response Number We do not agree with AZHOVC regarding their recommendation to In the draft record of decision, this section of Forest Service road that 2506 close a portion of FR42 east of Bartlett Lake and West of the the commenter is referencing is designated as a motorized trail open intersection with FR1069. While this route was significantly damaged to public access. following the fire this route is a historically significant and popular 4WD route. TRAL and several 4WD clubs believe that this section of trail can be restored with volunteer resources and potentially some grant funding. We request this route remain in the inventory and in holding (or admin) status until such time as TRAL can bring forward a proposal for restoring the trail. I am concerned that the proposed Plan closes road 18B in the Cave Forest Service Road (FSR) 18B is designated for decommissioning as 2515 Creek Ranger District, known as the Red Creek Road. Road 18B it is located in a perennial creek, which is one of the few cold water provides the only vehicle access to the Verde River between Chiles creeks on the Tonto National Forest. Excluding motor vehicle use on and Sheep's Crossing. Thus, road 18B provides critical access to this road will minimize effects to sensitive habitat for threatened and fisherman and boaters. Finally, I note that Congress, in creating and endangered species. Additionally, the route is in such bad condition, it defining the boundaries of the Mazatzal Wilderness Area, expressly is nearly impossible for emergency vehicle to access it. allowed for the river access by Road 18B to continue. I thus believe that unilaterally closing road 18B contravenes the express will of Congress on this point. I am concerned that the proposed Plan appears to close the Verde Forest Service Road (FSR) 18B is designated for decommissioning as 2516 River crossing at Childs and the 708 road leading from the crossing. it is located in a perennial creek, which is one of the few cold water The Verde River Crossing at Childs provides the only direct access to creeks on the Tonto National Forest. Excluding motor vehicle use on Bloody Basin for people residing in Pine and Strawberry. I also note this road will minimize effects to sensitive habitat for threatened and that the River Crossing at Childs has existed since the construction of endangered species. Additionally, the route is in such bad condition, it the power plant (over 100 years) and thus the public has significant is nearly impossible for emergency vehicle to access it. property rights in that crossing. Finally, I note that Congress, in creating and defining the boundaries of the Mazatzal Wilderness Area, expressly allowed for the river access at Childs to continue. I thus believe that unilaterally closing the river crossing at Childs contravenes the express will of Congress on this point. In Insert 4, route 413 north of Bartlett road (route 19?), travel access In the draft record of decision, Forest Service Road 413 is designated 5 should be eliminated north of the conjunction of Blue Wash and Camp as a motorized trail, as it is in an active wash and there is a waterfall Creek. This is an area of a perennial stream flow, and access may that is considered a plunge pool resulting in OHVs not being able to significantly impact the area. Access may also encourage camping access it. This will minimize effects to the resources. near a water source. This portion of the route does not provide any unique recreational activity.

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Comment Letter Original Comment Text Forest Service Response Number Decommission all other roads within the Verde Scenic River area Comment is an opinion and lacks "supporting reasons for the 2472 except FR 57 and FR 16. Id. at 23. responsible official to consider" per 36 CFR 218.2. In addition to Forest Service Roads (FSR) 16 and 57 designated open to motorized use, FSR 68G is designated as a motorized trail as it provides route connectivity. We recommend that the following routes be closed and Comment lacks specific "supporting reasons for the responsible official 2472 decommissioned due to significant and adverse impacts to cultural to consider" per 36 CFR 218.2 and more importantly, without site- and archaeological resources that is occurring and will continue to specific information is nearly impossible to address. The quantity and occur if these remain open to public use: 14 568 1618 17 574 1659 81 density of cultural sites on the Tonto National Forest is such that 699 1740 87 1063 1993 97C U1087 3127 120 1099 3158 312 1103 nearly every route likely comes in close proximity to a site or cultural 3165 409 1380 3170 449A 1530 3197 479 1555 3644A 497 1617 resource. In addition, without more detailed information, the sites implied by the commenter could be sites reported by the public that have not been confirmed by a Forest Service archeologist or para- archeologist. During the district meetings that looked at specific routes brought up by comments, these routes were also discussed. In many instances, neither Forest Service employees nor Arizona Game and Fish Department Game enforcement officers were aware of any cultural resources associated with these routes or any potential impacts from motor vehicle use. In instances where sites associated with the listed roads where known, site specific discussions took place. For instance, for the routes that the commenter listed that were located on either the Payson or Pleasant Valley ranger districts, the routes were in areas where a closure would be difficult as the associated topography allows for easy cross-country travel. If the route was closed, district staff were concerned that illegal cross-country travel would increase as the area is popular for recreation and hunting access. The Sycamore OHV Area includes an ephemeral wash that is tributary This comment is an opinion and lacks specific "supporting reasons for 2472 to Lower Sycamore Creek. Forest Road 403 lies within the wash the responsible official to consider" per 36 CFR 218.2. According to bottom until it joins Sycamore Creek. Approximately 4.5 miles of the Forest Service biologists, although Sonoran desert tortoises may channel of Sycamore Creek, extending upstream from the boundary inhabit desert washes and canyon bottoms, their preferred habitat is with Fort McDowell Indian Reservation, are included in the area. DEIS comprised of rocky, boulder-covered hills and mountains. Areas at 468. There have been significant impacts to this wash due to outside of this heavily used OHV area include much better suited motorized use, including recreational shooting damage, vegetation habitat. Additionally, given that this area has received extremely heavy removal, and trash. The areas just outside of the wash provide and sustained use for over 25 years, it is unlikely that any tortoise

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Comment Letter Original Comment Text Forest Service Response Number important habitat for desert tortoise, making removal of motorized use inhabit or shelter in this location. Consultation with Arizona Game and from this area of high importance. Fish Department non-game personnel confirm this assumption. FR 3456, 3456A, and 3456B following Log Corral Wash (which drains We applied the minimization criteria identified in 36 CFR 212.55(b) to 2472 into Bartlett Reservoir) and then follows Log Corral Canyon (which minimize damage to soil, watershed, vegetation, other Forest drains into Sycamore Creek) should all be decommissioned and resources, and disruption of wildlife habitats. Eliminating all routes in closed. This closure needs to occur from the west terminus at FR 393 close proximity to stream and river channels is not a viable alternative. all the way through to the east terminus with SR 87. Log Corral The analysis of all alternatives for stream crossings can be found in Canyon was once a beautiful riparian area until it was taken over by the “Hydrological Resources” section of chapter 3 in the final EIS and OHV users and laid to waste. OHV users cleared downed cottonwood that report in the project record. Forest Service Roads (FSR) 3456, trees from the canyon bottom by chaining them to 4WD vehicles. This 3456A, and 3456B are designated are motorized trails and provide the occurred around 1980. A once beautiful birding/wildlife area was only full-sized vehicle access for the area west of FSR 87 and north of overrun by OHV users. Alternative B shows FR 3456A and FR 3456B FSR 160. These routes allow for access for deer, bear, and quail as motorized trails. It makes little sense to list FR 3456 as hunters and day trips for OHVs. FSR 393 is closed to public access decommissioned and then leave 3456A and 3456B open to motorized west of where it intersects with FSR 3456. Other options for allowing travel. Log Corral Canyon is a riparian area and there should be no for motorized access are continually being considered to minimize the OHV use permitted here. effects of motor vehicle use in the area. Forest Road (FR) 303A should be completely decommissioned and Comment lacks specific "supporting reasons for the responsible official 2472 that section of FR 303B should be decommissioned north of the to consider" per 36 CFR 218.2 for the closure of Forest Service Road junction with FR 303A. There is evidence that FR 303A has illegal (FSR) 303A. Structures associated with range management, grazing structures that have been put in place in violation of NEPA. FR supposedly illegal or otherwise, are outside compliance with the final 303B should remain open along with that portion of FR 303B that is Travel Management Rule, and therefore not a part of the travel west of the junction with FR 303A. This will allow for access to management draft record of decision. Furthermore, a portion of FSR Gleason Flat for river runners and also allow an area that is open for 303A was decommissioned in 1990s. Upper Salt River Plan and the dispersed camping along the Salt River. remainder of FSR 303 is designated for motor vehicle use as it connects to FSR 303B—without which there would be no way to access it or Gleason Flat. FR 644 should be decommissioned north of the junction with FR 223. There are gates on Forest Service Road (FSR) 644 at the wilderness 2472 By closing FR 644 at this point user education and enforcement might boundary that are currently not locked. However, with the signing of better curtail motorized trespass into the Salt River Canyon the record of decision, motor vehicle access north of these gates will Wilderness Area. This is what Alternative B recommends. Alternative become illegal as they will be locked, directly addressing the B would help easily remedy the problem of wilderness trespass and commenter’s concern. In addition, decommissioning FSR 644 north of also help the TNF comply with minimization criteria related to user the intersection with FSR 223—a total of approximately 30 miles— conflicts and OHV use. would limit access in a large area south of the wilderness, an area used for recreation, hunting, permit management, camping, OHV, and river access.

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Comment Letter Original Comment Text Forest Service Response Number River Sheep Bridge. OHV users are also accessing the Verde River In the draft record of decision, Forest Service Road (FSR) 18B is 2472 Sheep Bridge at the east end and driving motorized vehicles across designated for decommissioning as it is located in a perennial creek, the bridge. Adequate physical barriers need to be put in place to which is one of the few cold water creeks on the Tonto National curtail motorized access to Verde River Trail # 11 at this point and Forest. Excluding motor vehicle use on this road will minimize effects additional enforcement is essential. The Verde River Sheep Bridge is to sensitive habitat for threatened and endangered species. a popular destination for motorized and non-motorized users alike and Additionally, the route is in such bad condition, it is nearly impossible Tonto National Forest needs to protect the natural and historical for emergency vehicle to access it. resources that exist at this location. See below photo of OHV skid mark on the deck of the Verde River Sheep Bridge. We support the administrative closure of FR 2206 (Fossil Springs Management of the Fossil Creek area that the commenter refers to 2472 Road). We support conversion of this road into a non-motorized has been delegated to the Coconino National Forest. As such, system trail as is considered in the Fossil Creek Comprehensive River designation of motor vehicle use will be decided in a separate NEPA Management Plan. The TNF should provide additional information to analysis. Maps in the final EIS have been updated to reflect the resolve the uncertainty about whether the parking lot at the end of FR correct information. 784 is still going to remain open as this is the point where FR 784 becomes non-motorized Trail # 18 (South Mail Trail). We are wondering if the plan to close Trail # 18 will also result in the closing of FR 784 and the obliteration of the parking area. If FR 784 is kept open we believe that better enforcement is necessary on this road to deal with the problem of overflow parking. The travel management plan, in conjunction with the Comprehensive River Management Plan, can help better protect the natural resources that exist in and along Fossil Creek, including the Outstandingly Remarkable Values. All four of the DEIS maps omit the recreational section of the designated Wild and Scenic Fossil Creek. The TNF and the general public would be better served if these two In the draft record of decision, Forest Service Roads (FSR) 3222, 2472 routes were decommissioned as motorized routes and turned into 3224, 3224D, and 3224A are designated for motor vehicle use as they non-motorized trails for hiking and equestrian use. This would require allow for recreational opportunity use. Specifically, FSRs 3222 and blocking both routes and partially obliterating them to prevent more 3224 allow access to known dispersed campsites, trailheads and resource damage from occurring. Alternative B shows FR 3222 and spread out dispersed recreation in order to minimize the impacts FR 3224 as being decommissioned, which we support. We agree that associated with recreation. the two adjacent routes, FR 3224D and FR 3224A should be left open as motorized routes as they appear to be in a highly disturbed area that contains quite a few decommissioned routes that do not have any numerical designations. However, we would like to see the unauthorized routes in the vicinity closed and decommissioned to

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Comment Letter Original Comment Text Forest Service Response Number restrict use to the FR 3224D and A, as intended. The Pleasant Valley Ranger District contains no front country, which is appropriate and should continue. We note that the Cienega Springs Trail # 145 and the lower section of The two trails the commenter mentions, #145 and #146, will not be 2472 the McFadden Horse Mountain Trail # 146 are shown as non- designated for motor vehicle use in the draft record of decision, and motorized trails in both Alternative B and C. We have observed will remain open to non-motorized users. With the prohibition of cross- motorized recreation on these two trails and would like to see steps country travel as required by the final Travel Management Rule, the taken to absolutely eliminate this activity through the construction of issues identified by the commenter should be addressed. Each barriers that cannot be easily removed. Rolling cut sections of logs alternative has a spreadsheet of every route from the existing into the trail has proved inadequate in the past. Pipe and rail physical condition (including the unauthorized routes) and a detailed description barricades need to be constructed at the start of McFadden Horse of what it becomes for that alternative. This information can be found Mountain Trial # 146 along the Young Highway and at the start of the in the project record. Cienega Springs Trail # 145 near Cienega Springs The decommissioned route at the eastern terminus of FR 235 needs In the draft record of decision, the route north of where Forest Service 2472 to be blocked and obliterated. This route heads north from the end of Road 235 ends is designated for decommissioning and will not show FR 235 and goes into one of the Sierra Ancha Contiguous IRAs. This open to motor vehicle use on the motor vehicle use map. However, the route used to have a number and is recommended for site-specific actions required to decommission the route will be decommissioning in both Alternative B and C. addressed in future environmental analysis in compliance with the National Environmental Policy Act. Routes within the area of the May, 2012 Sunflower Fire, which burned In the draft record of decision, Forest Service Road (FSR) 3722, where 2472 18,000 acres, should be closed to prevent erosion. We can support it intersects with FSR 3721 is designated for decommissioning to FR 3463 designated for administrative purposes only, if it is left open. minimize resource impacts. FSRs 25A, 201A, and 201B are We would like to see FR 25A, FR 3772, FR 201A, and FR 201B added designated as motorized trails to provide access for hunters and full- to that list of routes listed for administrative use only. Under Alternative sized 4x4 vehicles. The terrain that these roads pass through limits B, these routes would be listed as motorized trails. Due to the potential illegal route proliferation, minimizing impacts to adjacent resources. for resource damage, we believe these routes should be limited to use for Forest Service administrative purposes only. Alternative B would decommission FR 477A and FR 477B. We In the draft record of decision, Forest Service Road 477A/477B is 2472 support this designation. The crossing of the Verde River by route designated as a motorized trail as it provides access to the wilderness 477B is hard to locate and motorized vehicles attempting to cross the trailhead. By limiting OHV use, it would require visitors to hike an Verde River at this point will cause serious damage to the riparian additional 8 miles before entering the wilderness, which provides for resource that exists here. Route 477A needs to be physically blocked hunting opportunities for those that prefer to backpack over multiple where it diverges to the east from FR 479. Allowing motorized access days. This route also provides access to a native fish area that into this area will only encourage motorized trespass into the Mazatzal Arizona Game and Fish Department conducts surveys. Wilderness Area and the Patâs Shoe IRA adjacent to the southwest corner of the Mazatzal Wilderness Area. It appears that the ford

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Comment Letter Original Comment Text Forest Service Response Number crossing of the Verde River at route 3258 is being recommended for decommissioning in Alternative C and that motorized recreational traffic will be rerouted across the spillway of Horseshoe Dam. We support this. FR 213 (Tortilla Ranch/Well) is designated as a motorized trail in In the draft record of decision, FSR 213 is designated as a motorized 2472 Alternative C. We have observed motorized OHV users driving to the trail. Forest Service Road (FSR) 213 provides access to the trailhead end of this route and then following hiking trails into the Superstition for non-motorized recreation. As of October 2014, no indications of Wilderness Area and also following user created trails within the motor vehicle use past the trailhead into the wilderness area was Superstition Wilderness Area. This is illegal and must be remedied. observed. In addition, FSR 213 is 3.25 miles long, which would mean Under Alternative B, FR 213 is classified as a decommissioned, we that users would be required to hike that distance before even entering support this designation. the wilderness area. Furthermore, FSR 213 provides access to the windmill so it will not be considered for decommissioning. For FR 393 in the table above, we note that the maps in the DEIS Forest Service Road (FSR) 2143 is not within the wilderness 2472 show this route, along with FR 2138 and FR 2143 intruding into the boundary; it intersects with FSR 393 near the top of section 2 and designated Wilderness area. The Special Areas Specialist Report heads southwest. This road is designated for administrative use only states that the road (FR 393) and associated uses for a powerline and and provides access for maintenance of the transmission line. FSR ranching pre-date the Wilderness designation. However, the Forest 2138 is designated for decommissioning where it enters the wilderness Service can and should decommission these routes as described in area. FSR 393 originates south west of Bartlett Lake to where it Alternative B. If access is needed for powerline maintenance, the intersects with FSR 3456, this portion will be designated for issue should be specifically explained along with the anticipated administrative use only—in part to allow Arizona Public Service (APS) amount of use these routes will experience for specially permitted to service their Four Corners to Pinnacle Peak 345kV Power uses. Transmission Line—and not open for public motor vehicle use. From the intersection with FSR 3456 until it encounters the southeastern boundary of the Mazatzal Wilderness boundary, FSR 393 is designated as a motorized trail. For the 0.62 miles that 393 is within the Mazatzal Wildness boundary, FSR 393 is designated administrative use only in compliance with the special use permit issued to APS in 2012. (In terms of anticipated use of this section, APS traditionally surveys their transmission lines annually; however, use could increase based on maintenance needs and potential unforeseen emergencies.) Where FSR 393 exits the wilderness boundary near the northwest corner of section 2 until it intersection with FSR 627, it is designated as a motorized trail. Both the Wilderness Act of 1964 (P.L. 88-577) and the Arizona Wilderness Act of 1984 (P.L. 98-406) allow for this type of non-conforming use within the wilderness. In 1961 the Tonto National Forest authorized APS, via

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Comment Letter Original Comment Text Forest Service Response Number a special use permit, to maintain the Four Corners to Pinnacle Peak 345kV Power Transmission Line. As part of the special use permit, APS was authorized motor vehicle access to maintain this transmission line. One such route named in the original permit is Forest Service Road (FSR) 393, which originates near the Verde River southwest of Bartlett Lake and follows the transmission line northwesterly until FSR 393 connects with FSR 627 south of Cross Ranch—FSR 627 was originally State Highway 87 before it was realigned by the Arizona Department of Transportation. With passage of the Wilderness Act in 1964, the legal boundary for the Mazatzal Wilderness was drawn incorporating sections of both FSR 393 and part of the transmission line within the boundary—the maps used for the legal mapping where early 1950s quadrangle maps. A legal description with maps, prepared in 1970 that superseded the previous legal description, still showed both a portion of FSR 393 and the transmission line within the wilderness boundary. With the passage of the Arizona Wilderness Act of 1984, an updated legal description and maps were produced, superseding previous legal descriptions. In this version, the eastern boundary where is connects with the southern boundary was moved and the transmission lines where no longer within the designated wilderness boundary; however, the road continues to be within the wilderness boundary. FR 406B (3.65 miles) and 567B (3.38 miles) are both located within Forest Service Roads (FSR) 406B and 567B are designated 2472 the designated Wilderness. DEIS Special Areas Specialist Report at 7. administrative use only and will be closed to public use and travel Both routes allegedly provide access to private inholdings, however where they enter the wilderness. Use will continue to be permitted to such inholdings are not identified on any of the maps for this project. only the private inholding landowners in a manner that does not These routes should not be designated as open to the public and preclude access to the land. Section 1323(a) of ANILCA provides should be considered for decommissioning if the existing property property owners within the boundaries of the National Forest System owner supports such designations. certain rights of access across National Forest System lands. According to the terms of ANILCA, such access shall be “subject to such terms and conditions as the Secretary of Agriculture may prescribe,” and “as the Secretary deems adequate to secure to the owner the reasonable use and enjoyment thereof: Provided, That such owner comply with rules and regulations applicable to ingress and egress to or from the National Forest System” (16 U.S.C. 3210(a)). “While ANILCA provides certain rights to property owners, those rights are subject to such reasonable terms and conditions as the Forest

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Comment Letter Original Comment Text Forest Service Response Number Service may prescribe in a written authorization. Some property owners also may possess reserved or outstanding rights-of-way or other rights providing access across National Forest System lands, which may or may not require a written authorization from the Forest Service. Those rights must be recognized under § 212.55(d) … To the extent other provisions of ANILCA may address rights for motor vehicle access, they are covered by §212.55(d)(1), which requires that the responsible official recognize valid existing rights in making designations under the final rule” (Federal Register, Volume 70, Number 216, page 68282). Documentation for the current road use permits for these two roads is found in the project record at the Supervisor’s Office in Phoenix, Arizona. For FR 487A and FR 487B, the Special Areas Specialist report states In the draft record of decision, this road is designated administrative 2472 that these routes provide access to a private inholding however this use only and will be closed to public use and travel on it north past private inholding is not located within the Sierra Ancha Wilderness where it enters the Sierra Ancha Wilderness will be permitted to only to Area and it appears as if FR 2848 could provide the necessary access the Murphy Ranch private inholding in a manner that does not to this property. preclude access to the land. Section 1323(a) of ANILCA provides property owners within the boundaries of the National Forest System certain rights of access across National Forest System lands. According to the terms of ANILCA, such access shall be “subject to such terms and conditions as the Secretary of Agriculture may prescribe,” and “as the Secretary deems adequate to secure to the owner the reasonable use and enjoyment thereof: Provided, That such owner comply with rules and regulations applicable to ingress and egress to or from the National Forest System” (16 U.S.C. 3210(a)). “While ANILCA provides certain rights to property owners, those rights are subject to such reasonable terms and conditions as the Forest Service may prescribe in a written authorization. Some property owners also may possess reserved or outstanding rights-of-way or other rights providing access across National Forest System lands, which may or may not require a written authorization from the Forest Service. Those rights must be recognized under § 212.55(d). To the extent other provisions of ANILCA may address rights for motor vehicle access, they are covered by § 212.55(d)(1), which requires that the responsible official recognize valid existing rights in making designations under the final rule” (Federal Register, Volume 70, Number 216, page 68282). Documentation for the private inholding

128 Volume II–Response to Comments

Comment Letter Original Comment Text Forest Service Response Number that is accessed solely by FSR 487 is found in the project record at the Supervisor’s Office in Phoenix, Arizona. In the Salt River Canyon Wilderness Area FR 644A appears to intrude There are gates on Forest Service Road (FSR) 644 at the wilderness 2472 into the designated Wilderness area. For this route and all other routes boundary that are currently not locked. However, with the signing of that intrude into, rather than form the boundary of the Salt River the record of decision, motor vehicle access north of these gates will Canyon Wilderness area, the TNF must decommission and obliterate become illegal as they will be locked, directly addressing the these routes. commenter’s concern. The apparent intrusion that the commenter indicates will be addressed by this and the decommissioning of the route past the gates. FR 154, 1885, 507, 1661, W005, and 3044 are located within an IRA. As indicated in the Special Areas; Roadless Area Conservation; Final 2472 These routes should be closed. If the TNF proceeds with designating Rule, “This final rule will not close or otherwise block access to any of these routes as open, we ask for an explanation of the rationale for those roads; the final rule merely prohibits the construction of new opening these roads. roads and the reconstruction of existing roads in inventoried roadless areas. Under this final rule, management actions that do not require the construction of new roads will still be allowed, including activities such as timber harvesting for clearly defined, limited purposes, development of valid claims of locatable minerals, grazing of livestock, and off-highway vehicle use where specifically permitted. Existing classified roads in inventoried roadless areas may be maintained and used for these and other activities as well" (Federal Register, Volume 66, Number 9, page 3249). In the draft record of decision, Forest Service Roads (FSR) 154, 1885, and 1661 are designated as motorized trails open to full-sized vehicles as they provide for recreational opportunities in that area, such as hunting, along with providing access for rangeland management. FSRs 507 and 3044 are designated for decommissioning. W005 is not a route that we have in our database so we are unable to address the concerns surrounding this route. FR 1625 lies within an IRA. This route should be closed. If the TNF As indicated in the Special Areas; Roadless Area Conservation; Final 2472 proceeds with designating this route as open, we ask for an Rule, “This final rule will not close or otherwise block access to any of explanation of the rationale for opening this road. those roads; the final rule merely prohibits the construction of new roads and the reconstruction of existing roads in inventoried roadless areas. Under this final rule, management actions that do not require the construction of new roads will still be allowed, including activities such as timber harvesting for clearly defined, limited purposes, development of valid claims of locatable minerals, grazing of livestock,

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Comment Letter Original Comment Text Forest Service Response Number and off-highway vehicle use where specifically permitted. Existing classified roads in inventoried roadless areas may be maintained and used for these and other activities as well" (Federal Register, Volume 66, Number 9, page 3249). As such, the Forest Service does not intend to close this route to motorized access. This route is currently a ML 2 in the inventoried roadless area and will continue to be open to motor vehicle use as it provides recreational access connectivity, along with access to ranching improvements. FR 235. Portions of this route are located within an IRA and MSO As indicated in the Special Areas; Roadless Area Conservation; Final 2472 critical habitat. This route should be closed. If the TNF proceeds with Rule, “This final rule will not close or otherwise block access to any of designating this route as open, we ask for an explanation of the those roads; the final rule merely prohibits the construction of new rationale for opening this road. roads and the reconstruction of existing roads in inventoried roadless areas. Under this final rule, management actions that do not require the construction of new roads will still be allowed, including activities such as timber harvesting for clearly defined, limited purposes, development of valid claims of locatable minerals, grazing of livestock, and off-highway vehicle use where specifically permitted. Existing classified roads in inventoried roadless areas may be maintained and used for these and other activities as well" (Federal Register, Volume 66, Number 9, page 3249). Forest Service Road (FSR) 235 provides access to the Billy Lawrence Trailhead. This trailhead is for two non- motorized trails (Lucky Strike Trail 144 and Center Mountain Trail 142) that provide access to much of the northern and eastern sections of the Sierra Ancha Wilderness. This access will become even more critical since FSR 203 on the eastern side of the wilderness will be closed to all motor vehicle access. In addition, the effects from this route, along with appropriate mitigations associated with the effects to the Mexican spotted owl have already been addressed in the current Mexican spotted owl recovery plan. The Mexican spotted owl was analyzed under all alternatives in the final EIS and in the biological assessment for affects to the species Forestwide. This analysis can also be found in the final Wildlife and Plant Habitat Resources report in the project record. Convert FR 16 to a non-motorized trail at a location approximately The portion of Forest Service Road 16 that the commenter is referring 2472 one-eighth mile from the river and gate it to prevent motorized access to will not be designated for motor vehicle use to minimize the effects into riverbed and Mazatzal Wilderness. Id. at 32-33. to the resources associated with the river.

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Comment Letter Original Comment Text Forest Service Response Number The terminus of FR 25 on the east side of the Mazatzal Wilderness Once a motorized system has been designated and a motor vehicle 2472 Area has, for many years, been a source of intermittent motorized use map has been published, driving off of a designated route is not trespass. At the wilderness boundary FR 25 becomes Trail # 91. We permitted per the final Travel Management Rule. However, the area in have witnessed destruction of a grazing structure (corral) at the question, where Forest Service Road 25 ends at the wilderness wilderness boundary as well as brush cutting in an attempt to access boundary and the trailhead for hiking has been pipe railed to prevent the wilderness area. A more substantial barricade needs to be motorized incursions into the wilderness at this point. More information constructed at the terminus of FR 25 to solve this problem. Because of about enforcement of the designated motorized route system can be the need for trail access here, we would not recommend closing FR 25 found in the “Law Enforcement” section of the final EIS. in this area, rather creating a more substantial and effective barrier to delineate the wilderness boundary and the beginning of the non- motorized trail. Forest Road 1521 (Mine Mountain route) is a route into the Four As indicated in chapter 3 of the final EIS, “Wilderness, Wild and Scenic 2472 Peaks Wilderness Area. Alternative B calls for the decommissioning of Rivers, Inventoried Roadless Areas, and Special Management Areas” this route. We support this designation and believe it will better protect section, Forest Service Roads (FSR) 1521 and 401A are both outside the resources of this wilderness area. Forest Road 143 (Four Peaks the legal boundary of the wilderness as the legal description indicates Road) is a popular route both for the OHV community and those users that the wilderness boundary is 33 feet from center line on both sides wishing to access the Four Peaks Wilderness Area and the Boulder of these roads. FSR 143 is also outside the wilderness as the Inventoried Roadless Area. The area at the junction of FR 1521 and boundary is 33 feet from the center line of this road to the east. All FR 143 has become expanded by OHV use to the point where it is three of these routes are designated for motor vehicle use in the draft allowing and promoting motorized access into the Four Peaks record of decision. The final EIS has also added analysis of user Wilderness Area. This a user-created area is being trashed and is also conflict to the “Recreation” section of chapter 3. The possibility of pipe subject to littering. The TNF should consider fencing this area with the railing, or other such “adequate” barriers, along these routes to same type of heavy duty structures that currently exist at the junction decrease wilderness incursions and user conflict, along with additional of FR 143 and FR 401. This is also an area with significant user wilderness boundary signs, will be considered outside of this analysis conflict. with decisions at the district level. Forest Road 401A (Cane Springs route) is another route into the Four The possibility of pipe railing, or other such “adequate” barriers, along 2472 Peaks Wilderness Area. Alternative B calls for the decommissioning of these routes to decrease wilderness incursions and user conflict, along this route, which is an appropriate action that we fully support. FR with additional wilderness boundary signs, will be considered outside 401A is the source of many trespass issues into the Four Peaks this analysis and decision at the district level. As indicated in chapter Wilderness Area and decommissioning it would limit trespass and 3 of the FEIS, “Wilderness, Wild and Scenic Rivers, Inventoried better protect the wilderness and wilderness values. Based on the Roadless Areas, and Special Management Areas” section, Forest personal observations, the western terminus of the Lower Soldier Service Roads (FSR) 1521 and 401A are both outside the legal Camp Trail # 84 in Cottonwood Camp along Cottonwood Creek almost boundary of the wilderness as the legal description indicates that the routinely has the trail signs knocked down and fence barricades wilderness boundary is 33 feet from center line on both sides of these routinely cut and vandalized. There is a need at this location for the roads. FSR 143 is also outside the wilderness as the boundary is 33 type of heavy duty barriers that exist at the junction of FR 143 and FR

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Comment Letter Original Comment Text Forest Service Response Number 401. As one moves east along FR 401A one comes to the east feet from the center line of this road to the east. All three of these terminus of the Lower Soldier Camp Trail # 84 and the west terminus routes are designated for motor vehicle use. of the Soldier Camp Trail # 83. Trail signs and wilderness signs at both these locations are difficult to maintain as the signs are repeatedly removed or vandalized. Near the end of FR 401A you come to the Cane Springs Trail # 77. Again, at this location there is no trail sign, no The possibility of pipe railing, or other such “adequate” barriers, along 2472 wilderness sign, and no barricade to keep OHVs from trespassing into these routes to decrease wilderness incursions and user conflict, along the Four Peaks Wilderness Area. The TNF has a legal obligation to with additional wilderness boundary signs, will be considered outside keep motorized use out of this wilderness and off of this trail. At the this analysis and decision at the district level. As indicated in chapter end of FR 401A trespass routinely occurs into the Four Peaks 3 of the FEIS, “Wilderness, Wild and Scenic Rivers, Inventoried Wilderness Area because there is not an adequately constructed Roadless Areas, and Special Management Areas” section, Forest wilderness barricade at the west terminus of the Alder Creek Trail # Service Roads (FSR) 1521 and 401A are both outside the legal 82. The beginning of the Alder Creek Trail # 82 is an old jeep trail for boundary of the wilderness as the legal description indicates that the the first mile or so and we have observed pieces of motorized vehicles wilderness boundary is 33 feet from center line on both sides of these littering this trail. At all of these potential wilderness access points, the roads. FSR 143 is also outside the wilderness as the boundary is 33 TNF must provide adequate barriers and signage so as to curtail feet from the center line of this road to the east. In the draft record of motorized access into the Four Peaks Wilderness Area and make decision, all three of these routes are designated for motor vehicle enforcement more manageable. Perhaps the easiest way for Tonto use. More information about enforcement of the designated motorized National Forest to fulfill its legal obligation is to have the status of FR route system can be found in the “Law Enforcement” section of the 401A changed to decommissioned. We would also support final EIS. redesignation of FR 401A as a non-motorized system hiking trail similar to what was done with the old route into Reevis Ranch in the Superstition Wilderness Area. The old map on page 11 of the Recreation Report shows the Lime Comment is an opinion and lacks "supporting reasons for the 2472 Creek IRA as having an ROS rated as primitive. The new map on responsible official to consider" per 36 CFR 218.2. However, in the page 13 of the Recreation Report shows the Lime Creek IRA ROS draft record of decision, Forest Service Road 1530B is designated for rated as semi-primitive non-motorized. Anyone who has been to the administrative use only to allow for utility maintenance, resulting in no Lime Creek IRA can tell you that it is, in fact, primitive; if for no other public motor vehicle access. reason than the area has no system trails and has not been grazed for a very long time. The TNF cannot arbitrarily change the ROS for this area through this action. Route 1530B which is located just outside of the Lime Creek IRA should be listed as decommissioned, as proposed in Alternative B and C. This route is used by OHV users to access and damage the riparian values that exist within and just outside of this IRA in Lime Creek proper.

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Comment Letter Original Comment Text Forest Service Response Number There is a citizen proposed Uninventoried Roadless Area (URA) We are unaware of the "citizen proposed uninventoried roadless area" 2472 located within the Cave Creek Ranger District that is referred to the commenter is referencing. This route is designated open for public informally as the New Water Mountains/Squaw Creek area. This area motorized use because it provides access to private property, qualifies as having an ROS rated at primitive. Much of this area is regardless of current use of that property, and provides the only listed as a heritage gem as per the map on page 25 of the Recreation motorized access to the area for hunting and camping opportunities. It Report. We believe this area was unintentionally passed over in the also provides access to non-motorized trail #8. RARE II process back in the 1970s and should have been designated as an IRA. Alternative C shows FR 58 as open to motorized access. That section of FR 58 south of the junction with the decommissioned route 3168A should be decommissioned also. FR 58 has as its south terminus a small piece of private property that is called the Six Bar Ranch. However, this is an abandoned site and there is presently no functioning ranch at this location. Plan B shows that section of FR 58 that is south of route 3168A as decommissioned, which we support. Routes 1704 and 3715 should be decommissioned. Route 1704 is a Comment is an opinion and lacks "supporting reasons for the 2472 cherry-stemmed route into the Boulder IRA and route 3715 appears to responsible official to consider" per 36 CFR 218.2. In the draft record be wholly within the Boulder IRA as depicted on the map for of decision, Forest Service Roads (FSR) 1704 and 3715 are Alternative C. Both of these routes should be decommissioned, as designated for motor vehicle use as they provide access to that part of indicated in Alternative B. Just to the north of the Boulder IRA routes the Forest and provide access to range and wildlife management 22 (Bushnell Tank Road), 1452, 1451, 3529, 23, 5244, and 1693 structures. FSR 22 is designated for administrative use only to allow should be limited to administrative use only. Alternative C has made for necessary permitted uses by other agencies, such as the Arizona the correct determination on the status for these seven routes. If these Game and Fish Department and U.S. Geological Services, and ranch seven routes are allowed to revert to the status of motorized trails, maintenance by the permittee, while continuing to protect resources then this area will simply become another area that will be damaged impacted by the fire. All roads that intersect with this road will also be and overrun by uncontrolled and irresponsible OHV use. The Edge designated for administrative use only, unless designated for Complex Fire (July 2005, 71,635 acres) originally created the need for decommissioning. FSR 422/422A is designated as a motorized trail as these roads to be managed for administrative use only. FR 422 should it provides for recreational connectivity and for access for the remain open to the public as shown in Alternative C. Please note that permittee. We will attempt to correct section numbers and other map there is a section number confusion in this area between the DEIS errors as we are able to within the confines of our corporate database maps, USGS topographical maps, and the map for TNF. This should information. However, each alternative has a spreadsheet of every be clarified. route from the existing condition (including the unauthorized routes) and a detailed description of what it becomes for that alternative. This information can be found in the project record. The Ash Creek Wilderness Study Area includes the Ash Creek Currently, the Tonto National Forest does not manage for the area 2472 drainage as it extends out of the original Picacho IRA in a called “Ash Creek Wilderness Study Area” by the commenter as this southeasterly direction until it abuts the private property at Chrysotile. area is not recognized in the current 1985 Tonto Forest Plan.

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Comment Letter Original Comment Text Forest Service Response Number We would like to recommend that routes 3127 and 1052 be Sometime in 2013, a proposal was submitted by a representative of decommissioned north of their junction in section 24 (section 24 the local Sierra Club that outlined Tonto National Forest lands that remains in the same location on the Tonto National Forest map). Both could be proposed for wilderness inclusion. However, based on a map Alternatives B and C call for these two routes to remain open as submitted, these two roads are outside of the proposed area. While motorized trails. However, we believe that closure of these two routes we appreciate the recommendation and understand that wilderness is necessary to protect the riparian values that exist in the perennially designation is a congressional action, use of Forest Service Roads flowing Ash Creek and further the goal of resource protection in this (FSR) 3127 and 1052 where they interest north is not currently unique area. We support the decommissioning of FR 473A north of impacting natural resources and are primarily used by hunters, OHVs, the junction with FR 372 located in section 36. We also support the and permittees. These routes provide for motorized access into an decommissioning of FR 2293 north of the private property located in area that has limited motor vehicle access currently. In addition, we sections PB 43 and PB 46 (map A shows these routes as FR 382a, appreciate the support for decommissioning of FSRs that the FR 2296, and FR 2297). commenter mentions in the last two sentences of their comment. These routes are designated for decommissioning because there is no through access on the parcel of private property and there are other routes in the area that provide for similar recreational activities and access. We recommend that barriers be installed immediately beyond the As indicated in the legal description for the Superstition Wilderness, 2472 parking area that is adjacent to State Route 88 (Apache Trail) where Forest Service Road 213 is buffered 33 feet from the center line on access to FR 213 begins. There is no private property that exists at both sides of the road, making it outside of the wilderness boundary. the south terminus of FR 213 and cattle have not been grazed in this With the signing of the final decision, further analysis will need to be area for some time. Reclamation of non- motorized routes within the done at the district level to install barricades, as permitted by land Superstition Wilderness in this area will also need to be prioritized to authorization, and to obliterate routes designated for rectify past damage. decommissioning. We are aware that there are many unsurveyed unauthorized routes that will need restoration work. The priority of this work will be decided at the district level, based on staff and resource availability. We would like to recommend that routes 1827 and U1827A within the Forest Service Road 1827 is a recognized system road and is 2472 Black Cross Butte Inventoried Roadless Area (IRA) be classified as designated as a motorized trail to allow for hunter access. The decommissioned routes, as called for in Alternative B. Both of these topography that this road follows limits illegal route proliferation. routes appear to be user created and there is no indication that any U1827A is designated for decommissioning in the draft record of type of maintenance has ever occurred. decision. Roads 2886, 2812, 2813, 2812A are old mining roads that I have As detailed in the description of alternative C in the final EIS and in the 2482 wanted to explore for years. They are shown as closed. They are in an draft record of decision, the Cherry Creek Road (Forest Service Road inventoried roadless area. Again, how can you have an inventoried 203) has been designated as decommissioned and after site-specific roadless area with roads in it. I have never seen anyone using the analysis, will be blocked from motor vehicle travel south of where it roads, so there can’t be much damage on them. Until recently, I have first enters the Sierra Ancha Wilderness from the north, south of P.B.

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Comment Letter Original Comment Text Forest Service Response Number not had the time or a vehicle capable of exploring these roads. I want Creek and where it exits the wilderness area near Devils Chasm. Any to explore them. Driving on them will provide an impressive close-up existing routes that originate from FSR 203 between these points are view of the Sierra Ancha Mountains. also designated for decommissioning as there will be no way to access them. Forest Road 390 is listed as being proposed for declassification to In the draft record of decision, Forest Service Road (FSR) 390 is open 554 Motorized use only yet that road does not even exist. I stage for for motor vehicle use to Copper Creek to provide camping access volunteer work on the West end of Forest Road 44 at the "terminus" of away from FSR 269. South of this the route is designated for Forest Road 390 and it isn't there! Trust me! I know what I am talking decommissioning to minimize effects to resources in the area. about. Forest Road 390 is scheduled for closure (downgraded) yet it is a viable and used road. To the east between Perley and Hells Gate Canyon drainages is In the draft record of decision, Forest Service Road 144 is designated 2405 FS144 which is to remain open as a motorized trail under Alternative as a motorized trail as the commenter requested. Candas a ML2 road under Alternative D. This road accesses two FS wildlife guzzlers. The AES has no issue with this road being a motorized trail. Please note that FR114 is listed as open - but this is a private road Forest Service Road 114 is a private road and is not under the 30 and lawfully posted against trespass. authority of the Forest Service. In the draft EIS, we incorrectly identified it as a road that the Forest Service managed and proposed it as open to public access. I am almost certain the roads leading into my remote hunting spots will This comment lacks specific information and "supporting reasons for 9 be closed. I have hunted there for over 30 years, and as I get older I the responsible official to consider" per 36 CFR 218.2. No further can no longer hike the hills and venture too far from 2 tracks/ trails. response warranted. Therefore my input is that no change be mad to the current system Please keep roads and any off-road activities out of designated and As detailed in the description of alternative C and in the draft record of 1101 potential wilderness; for example, the Cherry Creek Road should be decision, the Cherry Creek Road (Forest Service Road 203) has been closed where it enters the Sierra Ancha Wilderness. designated as decommissioned and after site-specific analysis, will be blocked from motor vehicle travel south of where it first enters the Sierra Ancha Wilderness from the north, south of P.B. Creek and where it exits the wilderness area near Devils Chasm. First, is the road that cuts through the area of the Sierra Ancha It is believed that the commenter is describing Forest Service Road 1281 Wilderness on the left and the Inventoried Roadless Area on the right. 487/487A. This road is designated administrative use only and will be Plan B would decommission this road. One road begets another road, closed to public use and travel on it north past where it enters the ad infinitum. Protect this area to the maximum. Sierra Ancha Wilderness will be permitted to only to the Murphy Ranch private inholding in a manner that does not preclude access to the land. Section 1323(a) of ANILCA provides property owners within the

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Comment Letter Original Comment Text Forest Service Response Number boundaries of the National Forest System certain rights of access across National Forest System lands. According to the terms of ANILCA, such access shall be “subject to such terms and conditions as the Secretary of Agriculture may prescribe,” and “as the Secretary deems adequate to secure to the owner the reasonable use and enjoyment thereof: Provided, That such owner comply with rules and regulations applicable to ingress and egress to or from the National Forest System” (16 U.S.C. 3210(a)). “While ANILCA provides certain rights to property owners, those rights are subject to such reasonable terms and conditions as the Forest Service may prescribe in a written authorization. Some property owners also may possess reserved or outstanding rights-of-way or other rights providing access across National Forest System lands, which may or may not require a written authorization from the Forest Service. Those rights must be recognized under § 212.55(d) … To the extent other provisions of ANILCA may address rights for motor vehicle access, they are covered by § 212.55(d)(1), which requires that the responsible official recognize valid existing rights in making designations under the final rule” (Federal Register, Volume 70, Number 216, page 68282). Documentation for the private inholding that is accessed solely by FSR 487 is found in project record located at the Supervisor’s Office in Phoenix, Arizona. Route #203B (Cherry Creek Road on Sierra Ancha Wilderness, 10.05 Road 203B is a road within a designated wilderness and as such 2497 mile of road in wilderness)- this is proposed to be open in Alternative cannot legally be designated as open to motor vehicle use. Only Con Page 128 of the DEIS but is currently proposed for closure due to Congress can either allow a road to be designated within a wilderness guidance from the regional office. This is an important access road to or can change the boundaries of a wilderness to show a certain road the east side of the Sierra Anchas for hunters and other recreationists. as being outside a wilderness area. As such, detailed in the The Department requests route #203B remain open. description of alternative C and in the draft record of decision, the Cherry Creek Road (Forest Service Road 203) has been designated as decommissioned and after site-specific analysis, will be blocked from motor vehicle travel south of where it first enters the Sierra Ancha Wilderness from the north, south of P.B. Creek and where it exits the wilderness area near Devils Chasm. FR 487A, 203B, and other roads lead into Sierra Ancha Wilderness. As detailed in the description of alternative C and in the draft record of 2472 No motorized roads are allowed in wilderness areas. Both routes are decision, the Cherry Creek Road (Forest Service Road 203) has been designated as decommissioned and after site-specific analysis, will be

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Comment Letter Original Comment Text Forest Service Response Number also located within MSO critical habitat. These routes should be blocked from motor vehicle travel south of where it first enters the decommissioned and closed. Sierra Ancha Wilderness from the north (south of P.B. Creek) to where it exits the wilderness area near Devils Chasm. Forest Service Road (FSR) 487/487A is designated administrative use only and will be closed to public use and travel on it north past where it enters the Sierra Ancha Wilderness will be permitted to only to the Murphy Ranch private inholding in a manner that does not preclude access to the land. Section 1323(a) of ANILCA provides property owners within the boundaries of the National Forest System certain rights of access across National Forest System lands. According to the terms of ANILCA, such access shall be “subject to such terms and conditions as the Secretary of Agriculture may prescribe,” and “as the Secretary deems adequate to secure to the owner the reasonable use and enjoyment thereof: Provided, That such owner comply with rules and regulations applicable to ingress and egress to or from the National Forest System” (16 U.S.C. 3210(a)). “While ANILCA provides certain rights to property owners, those rights are subject to such reasonable terms and conditions as the Forest Service may prescribe in a written authorization. Some property owners also may possess reserved or outstanding rights-of-way or other rights providing access across National Forest System lands, which may or may not require a written authorization from the Forest Service. Those rights must be recognized under § 212.55(d) … To the extent other provisions of ANILCA may address rights for motor vehicle access, they are covered by § 212.55(d)(1), which requires that the responsible official recognize valid existing rights in making designations under the final rule” (Federal Register, Volume 70, Number 216, page 68282). Documentation for the private inholding that is accessed solely by FSR 487 is found in project record located at the Supervisor’s Office in Phoenix, Arizona. FR 1336, 12, and 1817 are located in the Goldfield IRA. These routes As shown in the draft record of decision and in the project record, are classified as ML2 roads in the no action alternative. We support Forest Service Roads (FSR) 1336 and 1817 are designated for the closure of all of these routes as in Alternative B and for the most decommissioning. FSR 12 is designated administrative use only within part Alternative C. However, we strongly object to the arbitrary the Goldfield Inventoried Roadless Area. conversion of Forest Service road FR 12 from a road to a motorized trail.

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Comment Letter Original Comment Text Forest Service Response Number FR 3519 is assigned a system number, however, it is classified as ML As shown in the draft record of decision and in the project record, unknown in the no action alternative. It is highly likely this route had Forest Service Roads (FSR) 3519 is designated for decommissioning been closed and/or decommissioned at same time in the past. Therefore, this route must be treated as a new route, new construction, or reconstruction, all of which are prohibited by the Roadless Rule. FR 560 & 603 are within a large roadless area (not inventoried by the The area that the commenter speaks of is managed as general forest Forest Service). This roadless area, informally known as New River and has not been identified as or designated by the Forest Service as Roadless Area, is approximately 58,000 acres. These routes should inventoried roadless area. Forest Service Roads 560 and 603 are be closed and decommissioned. Neither of these roads appear on the designated for motor vehicle use as these routes provide access to TNF forest map (revised 2004) and their origin and use is uncertain. In range allotment improvements and provide for recreation the no action alternative, these routes are labeled as ML2 roads. In opportunities. They were reclassified as motorized trails as part of the Alternative B and C they are arbitrarily reclassified as motorized trails review process that every route went through, as detailed in the draft and no explanation is provided as to why this was done. record of decision.

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Maps and GIS Data Comment Letter Original Comment Text Forest Service Response Number FR114 - Mountain Meadow Drive The Alternative C Map depicts our Thank you for bringing this to our attention. The needed edits to the 11 private Mountain Meadow Drive as a passenger car compatible OPEN database have been completed and the private property in questions, forest road (FR114). If this is not corrected before the final decision, and the road accessing it, shows as private and not Forest Service new forest maps will be printed that depict OUR PRIVATE ROAD as land on the draft record of decision map. an open Forest Road. I believe if this happens we will see an increase in recreational visitors driving into our community looking for access to the creek and places to camp. The other problem with the Alternative C Map is that it doesn't Thank you for bringing this to our attention. The needed edits to the 11 recognize our community as private land database have been completed and the private property in questions shows as private and not Forest Service land on the draft record of decision map. Please adjust your maps in whatever alternative is selected for the Thank you for bringing this to our attention. The needed edits to the 12 Travel Management Plan in regards to the following: · The road you database have been completed and the private property in questions, show as FR 114 north of the village of Christopher Creek is a and the road accessing it, shows as private and not Forest Service PRIVATE ROAD ON PRIVATE PROPERTY WITH NO ACCESS TO land on the draft record of decision map. U.S. FOREST LANDS. This road is posted NO TRESPASSING and should not be listed under any alternative as open to public travel. · The lands in the center of Section 20 north of Christopher Creek are private property owned by the members of SEE CANYON HOMES. These lands were acquired in a land exchange that occurred in 1990. All of your alternative maps show this land as USFS. Please correct your maps to the current land status - our private community does not wish to be bothered by members of the public attempting to recreate or camp on our private property because your forest maps are incorrectly marked. I recently learned that Alternate C incorrectly labels FR 114 as open Thank you for bringing this to our attention. The needed edits to the 1710 and suitable for all motor vehicles. On the contrary, the road, Mountain database have been completed and the private property in questions, Meadow Dr. is located on private land and isn't a public right-of-way. and the road accessing it, shows as private and not Forest Service lfs posted private and privately maintained for See Canyon homes, land on the draft record of decision map. The Brooks and Mountain Meadows subdivisions. The DEIS map needs to be corrected so the public doesn't confuse these properties with a public area they can freely recreate in.

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Comment Letter Original Comment Text Forest Service Response Number I request that you change the ownership designation on the maps to Thank you for bringing this to our attention. Where we are aware that 1710 show these properties are private. this problem exits, the needed edits to the database have been completed and the private property in questions shows as private and not Forest Service land on the draft record of decision map. In general, the Board supports and urges the TNF to implement Thank you for bringing this to our attention. The needed edits to the 1712 Alternative C, the preferred alternative; with some important database have been completed and the private property in questions, considerations as we move forward. These considerations are: 1. Alt. and the road accessing it, shows as private and not Forest Service C (as well as all other alternatives) incorrectly labels Forest Road 114 land as open and suitable for all motor vehicles. This is incorrect. This road, Mountain Meadow Dr. is not a public right-of-way. Indeed, it is posted private, privately maintained and services See Canyon Homes, The Brooks and Mountain Meadow subdivisions and does not service any portion of TNF lands. The DE IS maps need to be corrected now so the public does not confuse our private property with a public area they can freely recreate in. The See Canyon Homes private property is shown as TNF lands Thank you for bringing this to our attention. The needed edits to the 1712 according to the landownership legend on the various alternative database have been completed and the private property in questions maps. This is quite troubling to us. Please change the ownership shows as private and not Forest Service land on the draft record of designation on the maps to reflect our property as private and please decision map. do so c immediately. We have already have had members of the public attempting to camp and recreate on our private property and these incorrect maps only add further confusion. See Canyon Homes is listed on the various alternative maps as "See The map associated with the draft record of decision has been 1712 Canyon Summer Homes". This title is incorrect and we ask the TNF updated and shows this private inholding as "See Canyon." to list the title correctly to avoid future confusion. Why would we print a Travel map knowing that it is wrong. Comment is an opinion and lacks "supporting reasons for the 1715 responsible official to consider" per 36 CFR 218.2. No further response warranted. All your travel maps show that road 1938 connects. This is not true. At the scale of our alternative maps, Forest Service Road (FSR) 1938 1715 Road 1938 goes down a canyon to a wire corral and stops. It does not may show as connecting to FSR 894. Using the most updated aerial and it never has connected and if you see the country you know why. imagery, these routes appear to make a great looping alternative. It is very rough country. And now we are about to print new maps with However on the ground, 894 goes around the mountain and 1938 the same mistake. stops at a 1500 foot overlook. It is important for us to "ground truth" many routes before designation.

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Comment Letter Original Comment Text Forest Service Response Number I recently learned that Alternate C incorrectly labels FR 114 as open Thank you for bringing this to our attention. The needed edits to the 1718 and suitable for all motor vehicles. On the contrary, the road, Mountain database have been completed and the private property in questions, Meadow Dr. is located on private land and isn't a public right-of-way. and the road accessing it, shows as private and not Forest Service lfs posted private and privately maintained for See Canyon homes, land on the draft record of decision map. The Brooks and Mountain Meadows subdivisions. The DEIS map needs to be corrected so the public doesn't confuse these properties with a public area they can freely recreate in. I request that you change the ownership designation on the maps to Thank you for bringing this to our attention. Where we are aware that 1718 show these properties are private. Dealing with trespassers who this problem exits, the needed edits to the database have been ignore the signs are already a problem and this would only exacerbate completed and the private property in questions shows as private and it. not Forest Service land on the draft record of decision map. On all your maps you show road 1387 that goes through our yard and Thank you for bringing this to our attention. The needed edits the 1715 on to Young, Arizona. That one is correct. However we have a locked database have been completed and these routes have been electronic gate coming into the ranch. If people call us and tell us designated as administrative use only, unless there is an existing when they are coming in, we give them the combination. We do this easement that allows for public to travel through the private property. because we believe the multiple use of public lands. Once we have attained an easement, we will review designating the route for public motor vehicle use. All your travel maps show that road 1938 connects. This is not true. Thank you for bringing this to our attention. The needed edits the 1715 Road 1938 goes down a canyon to a wire corral and stops. It does not database have been completed and this route now terminates within and it never has connected and if you see the country you know why. section 35 and does not show as a loop opportunity. It is very rough country. And now we are about to print new maps with the same mistake. The current Tonto National Forest map, Revised 2004, and our on-line The current Tonto National Forest map, Revised 2004, and our on-line 5 map both do show that routes 1521 and 401A are "cherry stems" into map both do show that routes 1521 and 401A are "cherry stems" into the Four Peaks Wilderness and therefore do not violate the wilderness the Four Peaks Wilderness and therefore do not violate the wilderness area regulations. At the scale of the alternative maps, these routes will area regulations. At the scale of the alternative maps, these routes will not shop as "cherry stemed". not display with the buffer that indicates that they are "cherry stemmed". Table 17 Alternative B has 1,039 miles of roads that need to Thank you for catching this editing error in our draft EIS. We have 2471 maintained, not 1,507 as stated in the table. DEIS at 77. updated the corresponding table in the final EIS to reflect the correct total for roads under alternative B. Mileage totals in Tables 23-26 are incorrect. DEIS at 80-82. Thank you for catching these editing errors in our draft EIS. We have 2471 updated the corresponding tables in the final EIS to reflect the correct total for all four tables

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Comment Letter Original Comment Text Forest Service Response Number The maps you provided for users to make comments from are difficult We understand that the maps for this project can be difficult to read, as 2482 to reference. The road numbers used do not match the TNF map that they have a lot of information to convey in relationship to designating is sold to the public, there are no latitude and longitude lines to enable motor vehicle use on the Tonto National Forest. The maps for each us to reference GPS coordinates. alternative have township, range, and sections that are based on principal meridians. As part of communicating the spatial information for this project with the public, we attempted to integrate the information with Google Earth. However, we were unsuccessful with getting the two interfaces to communicate properly. GIS data for this project can be found in the project record or can be requested from the Supervisor's Office of the Tonto National Forest. The U.S. Forest Service should display the following disclaimer on its The intent of this project is to designate motor vehicle use on the Tonto 2496 TMP maps: DISCLAIMER: Arizona's Trust Land is managed by the National Forest in compliance with the final Travel Management Rule. Arizona State Land Department. Trust land is NOT public land. An Maps developed for this project will focus exclusively on the project OHV Decal allows crossing Trust Land when operating on existing area, which is the Tonto National Forest. Motor vehicle use on other roads and trails and on designated routes (unless otherwise lands will not be portrayed because the Forest Service has no prohibited). A recreation permit is required to park and stage your authorization outside the Forest boundary. As such, no disclaimers OHV, camp, hike, or conduct any recreational activity on Trust Land. associated with land outside of Forest Service jurisdiction will be included on any maps for this project. The legend should label this land as "State Trust Land". The intent of this project is to designate motor vehicle use on the Tonto 2496 National Forest in compliance with the final Travel Management Rule. Maps developed for this project will focus exclusively on the project area, which is the Tonto National Forest. State lands that are represented on the alternative maps are indicated by a single color and are not further identified. Accurate mapping to identify roads, trails and usage; Comment lacks "supporting reasons for the responsible official to 2500 consider" per 36 CFR 218.2. No further response warranted. Alternative C is identified in the Draft EIS as the preferred alternative. At the scale of the alternative maps, it is impossible to communicate 5 On page 35 of the draft EIS, it is stated "The most notable change the three different categories for motorized trails: single track; less than from the February 2013 proposed action is the designation of 60 inches; and full-sized vehicles. In chapter 3 of the final EIS, most of motorized trails for vehicles over 50 inches in width." However on the the resources analyzed motorized trails together; however, in some Alternative C map, there is no indication of which routes are opened to instances, such as in the recreation section, these trails are analyzed full size vehicles (i.e. vehicles over 50 inches in width), therefore it is separately. GIS data, including where the different types of motorized impossible to determine the environmental impact due to the different trails are located within the Forest, can be found in the project record type of vehicle usage. or can be requested from the Supervisor's Office of the Tonto National Forest.

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Comment Letter Original Comment Text Forest Service Response Number We understand the TMP ALT "C" map presently on the TNF web is When the draft EIS was release for comment, the maps made 1234 the old original map not showing the new changes as a results of the available electronically at http://data.ecosystem- previous comments and input provided over the years. . management.org/nepaweb/fs-usda-pop.php?project=28967 reflected all the public involvement up to that point, as detailed in chapter 2 of the draft EIS for alternative C. The same is true of the alternative C map for the final EIS. I noticed some typo problems with your Alternative B map. It shows Thank you for pointing this out. It has been addressed in the final EIS. 23 FR172A open, but FR172 that is used to get to FR172A is to be closed. And many of the motorized roads in that area have no access since the access roads are to be removed. We would like to see all rivers and major streams delineated in some With all of the data necessary to display on the alternative maps to 2472 fashion on the DEIS maps. This would more easily facilitate an visually articulate each alternative’s proposed motorized system, the understanding of the relationship between the road network and the addition of the suggested waterways in not possible. However, in riparian corridors. chapter 3 of the final EIS, motorized route proximity is analyzed for several resources, including hydrological and wildlife habitat. In addition, GIS data for this project can be found in the project record or can be requested from the Supervisor's Office of the Tonto National Forest. Whatever the option's PDF maps are, they're even worse than what We understand that the maps for this project can be difficult to read, as 31 you had a couple of years ago. I really have no idea what trails/roads they have a lot of information to convey in relationship to designating are in any of the proposals based on viewing the PDFs. Can't you motor vehicle use on the Tonto National Forest. The maps for each work with google maps or something similar alternative have township, range, and sections that are based on principal meridians. As part of communicating the spatial information for this project with the public, we attempted to integrate the information with Google Earth. However, we were unsuccessful with getting the two interfaces to communicate properly. GIS data for this project can be found in the project record or can be requested from the Supervisor's Office of the Tonto National Forest.

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Implementation Comment Letter Original Comment Text Forest Service Response Number Signs in Spanish should be incorporated with the new signs that have Forest Service (FSM) policy regarding signs and posters is contained 6 flooded the entrance way to the river and park. in Forest Service Manual 7100, chapter 7160—Signs and Posters. Section 1.3 states “Signage should consider the needs of persons with disabilities or non-English speaking users when and where appropriate. Use of languages other than English on signs is not appropriate.” The Tonto National Forest signage complies with this policy. The proposed plan C has added Alpha-Numeric routes to the Tonto. A The existing Forest road system does include some alpha numeric 554 bad idea. This is a significant cost increase for the Forest because designations. However, the renumbering of the routes after the final now the Agency will have to stock dual lettering books EIS is complete and the decision is signed will greatly reduce what is currently shown on the maps. The prudent plan, as currently used in the sector under discussion, Comment is an opinion and lacks "supporting reasons for the 554 would be to stay with a Numeric numbering system only. responsible official to consider" per 36 CFR 218.2. No further response warranted. All trails and roads that will be used for travel need to be properly The purpose of the EIS is to designate a system of roads and trails for 1983 marked with road and or trail numbers and usage; motorized use as is required by the Travel Management Rule. Implementation, including enforcement, of a travel management decision will be completed to the extent possible based on available resources. We plan to work in coordination with other Federal, State, and county agencies for enforcement and implementation of this decision. In addition, we have already begun coordinating with stakeholder groups to accomplish this on the ground. Accurate mapping to identify roads, trails and usage; In accordance with CFR 36 212.56 "Designated roads, trails, and 1983 areas shall be identified on a motor vehicle use map. Motor vehicle use maps shall be made available to the public at the headquarters of corresponding administrative units and Ranger Districts of the National Forest System and, as soon as practicable, on the website of corresponding administrative units and Ranger Districts. The motor vehicle use maps shall specify the classes of vehicles and, if appropriate, the times of year for which use is designated.” Utilize signs, press releases, and other forms of communication to Motor vehicle use maps will be available at local Forest Service offices 2472 inform the public of the standards adopted in the Management Plan. and, as soon as practicable, on Forest Service websites. The Forest Id. at 33. Including installing road and trail signs. Id. at 19. Service has additional travel management guidance in its sign

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Comment Letter Original Comment Text Forest Service Response Number handbook to ensure consistent messages and use of standard interagency symbols for use during implementation. MVUM are essentially impossible to interpret and it is unreasonable to According to the final Travel Management Rule, "Designated roads, 2497 expect the public to follow one. The Department requests all open trails, and areas shall be identified on a motor vehicle use map" 36 roads and motorized trails be signed/marked open by the current CFR 212.56. Additionally, "However, the final rule will enhance numbering system, and all roads and motorized trails to be closed enforcement by substituting a regulatory prohibition for closure orders clearly marked as such and providing for a motor vehicle use map supplemented by signage" (Federal Register, Volume 70, Number 216, page 68270). A map (even one that is infinitely better than what we are proposing) is not an enforcement strategy that our enforcement officers believe will succeed on its own. We need an excellent map and we have plans to augment the required map with more detailed maps depicting popular areas. We anticipate providing digital mediums as well. We believe that making a digital map compatible with GPS units is a good strategy. We need signs and/or physical barriers on the ground to enforce adequately. This is addressed as one of the minimum requirements in the Law Enforcement report in the final EIS. All trails and roads that will be used for travel need to be properly We welcome and are thankful for any volunteer assistance from the 2500 marked with road and or trail numbers and usage; Volunteers from public and users groups. Implementation of the decision will be an Payson will assist in placement of signage. undertaking that will likely take time. Motor vehicle use maps will be available at local Forest Service offices and, as soon as practicable, on Forest Service websites. The Forest Service has additional travel management guidance in its sign handbook to ensure consistent messages and use of standard interagency symbols for use during implementation. Minimal enforcement would be necessary if there was adequate Comment is an opinion and lacks "supporting reasons for the 2500 signage placed in areas of travel. responsible official to consider" per 36 CFR 218.2. It will likely take more than signs for the public to comply with the decision. We will also focus on education and partnerships, in addition to signs and law enforcement. Areas created for off-road users should be designed and maintained Using the minimization criteria from the final Travel Management Rule 33 by the Forest Service using best-management practices with the goal (36 CFR 212.55(b)), the designated OHV areas in the draft record of of minimizing environmental impacts. decision were analyzed to determine effects and to minimize them where possible. If resource damage or user conflicts, or other arise

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Comment Letter Original Comment Text Forest Service Response Number from these areas, they will be evaluated and managed according to Forest Service policy, which includes best management practices. Any areas that are designated for off-road users should be designed Using the minimization criteria from the final Travel Management Rule 1101 and maintained by the Forest Service to minimize environmental (36 CFR 212.55(b)), the designated OHV areas in the draft record of impacts. decision were analyzed to determine effects and to minimize them where possible. If resource damage or user conflicts, or other arise from these areas, they will be evaluated and managed according to Forest Service policy, which includes best management practices. Without enforcement, education, accurate mapping and proper Comment is an opinion and lacks "supporting reasons for the 1983 signage the Travel Management Plan is only worth the paper it is responsible official to consider" per 36 CFR 218.2. No further written on; response warranted. Without enforcement, education, accurate mapping and proper Comment is an opinion and lacks "supporting reasons for the 2500 signage the Travel Management Plan is only worth the paper it is responsible official to consider" per 36 CFR 218.2. No further written on; response warranted. Currently, the Coconino, Kaibab, Prescott, Coronado, Tonto, and The Tonto National Forest is working closely with cooperating agency 2497 Apache/Sitgreaves national forests have TMPs established under the Arizona Game and Fish Department to identify where the Forest can 2005 Travel Management Rule and their respective Land and be consistent with other forests' travel management decision while Resource Management Plans. However, there is little consistency taking into consideration unique conditions that the Tonto faces being between these plans making it difficult for Forest users to understand so close to such a large metropolitan area. While consistency across and comply with travel management regulations. It is important that all all Arizona forests would be ideal, the Tonto would like users and other forests provide clear and consistent direction pertaining to: motorized agencies to recognize the unique situation it faces when managing dispersed camping distances; consistency in which species of big motor vehicle use on the Forest. We strive to balance the need for game may be lawfully retrieved by motorized means; and consistency to better serve the public with the unique management improvements to the motorized vehicle use maps (MVUM) so they can situation that the Tonto faces. be easily used by the recreating public. Travel Management inconsistencies have challenged the Department's and other law enforcement agencies' ability to provide fair and uniform law enforcement and has prompted state legislation (House Bill 2551 signed by the Governor of Arizona on June 19, 2013) limiting state enforcement of travel management regulations. At the very least an implementation process needs to include the Comment is an opinion and lacks "supporting reasons for the 2405 ability to update maps based on this and other information. responsible official to consider" per 36 CFR 218.2. No further response warranted.

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Invasive Species Comment Letter Original Comment Text Forest Service Response Number The analysis included in the DEIS for noxious/invasive weeds only The analysis was done in compliance with Forest Service Manual for 2472 speaks to acres of weeds that would be accessible to OHV Noxious Weed Management (FSM 2900.03), which requires that the use/motorized access. This is not sufficient. The analysis should focus Forest determine the risk of introducing, establishing, or spreading on the likelihood of spread, introduction, removal, effect on eradication invasive species associated with any proposed action, as an integral efforts, and new/larger areas exposed due to the proposed component of project planning and analysis, and where necessary, designation of routes and areas in each alternative. See DEIS at 452. provide for alternatives or mitigation measures to reduce or eliminate that risk prior to project approval. The analysis in the final EIS has been further developed to directly address the commenter’s concern. This information is in the final Noxious/Invasive Weeds report in the project record and the summary of this information in chapter 3 of the final EIS.

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Power Company and Utilities Comment Letter Original Comment Text Forest Service Response Number One assumption that was made was that APS as a regulated utility As indicated in the final Travel Management Rule, “Use of a road or 2488 would have access to your roads proposed to be designated as trail that is authorized by a legally documented right-of-way held by a "Admin", as this is standard practice on other forests within the state. State, county, or other local public road authority” (36 CFR Please confirm. 212.51(a)(8)) is exempt from motor vehicle use. Under the authority of the Federal Land Policy and Management Act of 1976 as amended (P.L. 94-579) Sec. 501. [43 U.S.C. 1761] (a) The Secretary, with respect to the public lands (including public lands, as defined in section 103(e) of this Act, which are reserved from entry pursuant to section 24 of the Federal Power Act (16 U.S.C. 818)) [P.L. 102-486, 1992] and, the Secretary of Agriculture, with respect to lands within the National Forest System (except in each case land designated as wilderness), are authorized to grant, issue, or renew rights-or-way over, upon, under, or through such lands for– (4) systems for generation, transmission, and distribution of electric energy, except that the applicant shall also comply with all applicable requirements of the Federal Energy Regulatory Commission under the Federal Power Act, including part I thereof (41 Stat. 1063, 16 U.S.C. 791a-825r) [P.L. 102-486, 1992]; and further in Sec. 504. [43 U.S.C. 1764] (a) The Secretary concerned shall specify the boundaries of each right-of-way as precisely as is practical. Each right-of-way shall be limited to the ground which the Secretary concerned determines (1) will be occupied by facilities which constitute the project for which the right- of-way is granted, issued, or renewed, (2) to be necessary for the operation or maintenance of the project, (3) to be necessary to protect the public safety, and (4) will do no unnecessary damage to the environment. The Secretary concerned may authorize the temporary use of such additional lands as he determines to be reasonably necessary for the construction, operation, maintenance, or termination of the project or a portion thereof, or for access thereto. SRP requests that administrative access be retained at the end of FR The route that the commenter refers is designated for administrative 2489 1.530A near Horseshoe Reservoir to allow access to the Lime Creek use only. As part of Salt River Project’s permitted use of the Forest, Fish Barrier. access to this route will be determined outside of this travel management decision. Under the authority of the Federal Land Policy and Management Act of 1976 as amended (P.L. 94-579) Sec. 501. [43 U.S.C. 1761] (a) The Secretary, with respect to the public lands

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Comment Letter Original Comment Text Forest Service Response Number (including public lands, as defined in section 103(e) of this Act, which are reserved from entry pursuant to section 24 of the Federal Power Act (16 U.S.C. 818)) [P.L. 102-486, 1992] and, the Secretary of Agriculture, with respect to lands within the National Forest System (except in each case land designated as wilderness), are authorized to grant, issue, or renew rights-or-way over, upon, under, or through such lands for– (4) systems for generation, transmission, and distribution of electric energy, except that the applicant shall also comply with all applicable requirements of the Federal Energy Regulatory Commission under the Federal Power Act, including part I thereof (41 Stat. 1063, 16 U.S.C. 791a-825r) [P.L. 102-486, 1992]; and further in Sec. 504. [43 U.S.C. 1764] (a) The Secretary concerned shall specify the boundaries of each right-of-way as precisely as is practical. Each right-of-way shall be limited to the ground which the Secretary concerned determines (1) will be occupied by facilities which constitute the project for which the right-of-way is granted, issued, or renewed, (2) to be necessary for the operation or maintenance of the project, (3) to be necessary to protect the public safety, and (4) will do no unnecessary damage to the environment. The Secretary concerned may authorize the temporary use of such additional lands as he determines to be reasonably necessary for the construction, operation, maintenance, or termination of the project or a portion thereof, or for access thereto. SRP requests that administrative access for ATVs be retained at the The route that the commenter refers is designated for administrative 2489 end of FR 1530A to allow for maintenance and monitoring activities at use only. As part of Salt River Project’s permitted use of the Forest, the lime Creek Fish Barrier on lime Creek. This segment is designated access to this route will be determined outside of this travel under Alternative Cas administrative access, Alternative D as open, management decision. Under the authority of the Federal Land Policy and Alternative B as closed. SRP and the Arizona Game & Fish and Management Act of 1976 as amended (P.L. 94-579) Sec. 501. Department use ATVs on this segment of the road periodically when [43 U.S.C. 1761] (a) The Secretary, with respect to the public lands conducting necessary maintenance and monitoring activities at the (including public lands, as defined in section 103(e) of this Act, which lime Creek Barrier, as required under the H-BHCP and associated ITP are reserved from entry pursuant to section 24 of the Federal Power from the U.S. Fish and Wildlife Service. Act (16 U.S.C. 818)) [P.L. 102-486, 1992] and, the Secretary of Agriculture, with respect to lands within the National Forest System (except in each case land designated as wilderness), are authorized to grant, issue, or renew rights-or-way over, upon, under, or through such lands for– (4) systems for generation, transmission, and distribution of electric energy, except that the applicant shall also

149 Travel Management on the Tonto National Forest

Comment Letter Original Comment Text Forest Service Response Number comply with all applicable requirements of the Federal Energy Regulatory Commission under the Federal Power Act, including part I thereof (41 Stat. 1063, 16 U.S.C. 791a-825r) [P.L. 102-486, 1992]; and further in Sec. 504. [43 U.S.C. 1764] (a) The Secretary concerned shall specify the boundaries of each right-of-way as precisely as is practical. Each right-of-way shall be limited to the ground which the Secretary concerned determines (1) will be occupied by facilities which constitute the project for which the right-of-way is granted, issued, or renewed, (2) to be necessary for the operation or maintenance of the project, (3) to be necessary to protect the public safety, and (4) will do no unnecessary damage to the environment. The Secretary concerned may authorize the temporary use of such additional lands as he determines to be reasonably necessary for the construction, operation, maintenance, or termination of the project or a portion thereof, or for access thereto. Attachment A Route segments proposed for decommissioning that The routes that the commenter refers are either designated for 2489 SRP is requesting administrative access* administrative use only or are open to the public. As part of Salt River Project’s permitted use of the Forest, access to administrative use only routes will be determined outside of this travel management decision. Under the authority of the Federal Land Policy and Management Act of 1976 as amended (P.L. 94-579) Sec. 501. [43 U.S.C. 1761] (a) The Secretary, with respect to the public lands (including public lands, as defined in section 103(e) of this Act, which are reserved from entry pursuant to section 24 of the Federal Power Act (16 U.S.C. 818)) [P.L. 102-486, 1992] and, the Secretary of Agriculture, with respect to lands within the National Forest System (except in each case land designated as wilderness), are authorized to grant, issue, or renew rights-or-way over, upon, under, or through such lands for– (4) systems for generation, transmission, and distribution of electric energy, except that the applicant shall also comply with all applicable requirements of the Federal Energy Regulatory Commission under the Federal Power Act, including part I thereof (41 Stat. 1063, 16 U.S.C. 791a-825r) [P.L. 102-486, 1992]; and further in Sec. 504. [43 U.S.C. 1764] (a) The Secretary concerned shall specify the boundaries of each right-of-way as precisely as is practical. Each right-of-way shall be limited to the ground which the Secretary concerned determines (1) will be occupied by facilities

150 Volume II–Response to Comments

Comment Letter Original Comment Text Forest Service Response Number which constitute the project for which the right-of-way is granted, issued, or renewed, (2) to be necessary for the operation or maintenance of the project, (3) to be necessary to protect the public safety, and (4) will do no unnecessary damage to the environment. The Secretary concerned may authorize the temporary use of such additional lands as he determines to be reasonably necessary for the construction, operation, maintenance, or termination of the project or a portion thereof, or for access thereto. SRP is requesting administrative access to these route segments. The routes that the commenter refers are either designated for 2489 However, many of the segments are quite long; SRP is requesting administrative use only or are open to the public. As part of Salt River access only to the utility corridor Right-of-Way. Project’s permitted use of the Forest, access to administrative use only routes will be determined outside of this travel management decision. Under the authority of the Federal Land Policy and Management Act of 1976 as amended (P.L. 94-579) Sec. 501. [43 U.S.C. 1761] (a) The Secretary, with respect to the public lands (including public lands, as defined in section 103(e) of this Act, which are reserved from entry pursuant to section 24 of the Federal Power Act (16 U.S.C. 818)) [P.L. 102-486, 1992] and, the Secretary of Agriculture, with respect to lands within the National Forest System (except in each case land designated as wilderness), are authorized to grant, issue, or renew rights-or-way over, upon, under, or through such lands for– (4) systems for generation, transmission, and distribution of electric energy, except that the applicant shall also comply with all applicable requirements of the Federal Energy Regulatory Commission under the Federal Power Act, including part I thereof (41 Stat. 1063, 16 U.S.C. 791a-825r) [P.L. 102-486, 1992]; and further in Sec. 504. [43 U.S.C. 1764] (a) The Secretary concerned shall specify the boundaries of each right-of-way as precisely as is practical. Each right-of-way shall be limited to the ground which the Secretary concerned determines (1) will be occupied by facilities which constitute the project for which the right-of-way is granted, issued, or renewed, (2) to be necessary for the operation or maintenance of the project, (3) to be necessary to protect the public safety, and (4) will do no unnecessary damage to the environment. The Secretary concerned may authorize the temporary use of such additional lands as he determines to be reasonably necessary for the

151 Travel Management on the Tonto National Forest

Comment Letter Original Comment Text Forest Service Response Number construction, operation, maintenance, or termination of the project or a portion thereof, or for access thereto. Under Alternative C, the preferred alternative (a modified version of the As indicated in the final Travel Management Rule, “Use of a road or 2489 proposed action identified in public seeping in February 2013), 63 route trail that is authorized by a legally documented right-of-way held by a segments have been proposed for decommissioning that SRP is State, county, or other local public road authority” (36 CFR requesting be retained under an administrative access designation. 212.51(a)(8)) is exempt from motor vehicle use. Under the authority of Under Alternative B there are 111 route segments, and under the Federal Land Policy and Management Act of 1976 as amended Alternative D there are 22 route segments that are similarly proposed (P.L. 94-579) Sec. 501. [43 U.S.C. 1761] (a) The Secretary, with for decommissioning that SRP is requesting be retained under an respect to the public lands (including public lands, as defined in administrative access designation. section 103(e) of this Act, which are reserved from entry pursuant to section 24 of the Federal Power Act (16 U.S.C. 818)) [P.L. 102-486, 1992] and, the Secretary of Agriculture, with respect to lands within the National Forest System (except in each case land designated as wilderness), are authorized to grant, issue, or renew rights-or-way over, upon, under, or through such lands for– (4) systems for generation, transmission, and distribution of electric energy, except that the applicant shall also comply with all applicable requirements of the Federal Energy Regulatory Commission under the Federal Power Act, including part I thereof (41 Stat. 1063, 16 U.S.C. 791a-825r) [P.L. 102-486, 1992]; and further in Sec. 504. [43 U.S.C. 1764] (a) The Secretary concerned shall specify the boundaries of each right-of-way as precisely as is practical. Each right-of-way shall be limited to the ground which the Secretary concerned determines (1) will be occupied by facilities which constitute the project for which the right- of-way is granted, issued, or renewed, (2) to be necessary for the operation or maintenance of the project, (3) to be necessary to protect the public safety, and (4) will do no unnecessary damage to the environment. The Secretary concerned may authorize the temporary use of such additional lands as he determines to be reasonably necessary for the construction, operation, maintenance, or termination of the project or a portion thereof, or for access thereto. After careful review of Alt. C of the DEIS, there are several (46 in total) As indicated in the final Travel Management Rule, “Use of a road or 2488 existing roads being proposed for decommission that APS relies upon trail that is authorized by a legally documented right-of-way held by a for access into our various rights-of-way for transmission and State, county, or other local public road authority” (36 CFR distribution power lines. 212.51(a)(8)) is exempt from motor vehicle use. Under the authority of the Federal Land Policy and Management Act of 1976 as amended

152 Volume II–Response to Comments

Comment Letter Original Comment Text Forest Service Response Number (P.L. 94-579) Sec. 501. [43 U.S.C. 1761] (a) The Secretary, with respect to the public lands (including public lands, as defined in section 103(e) of this Act, which are reserved from entry pursuant to section 24 of the Federal Power Act (16 U.S.C. 818)) [P.L. 102-486, 1992] and, the Secretary of Agriculture, with respect to lands within the National Forest System (except in each case land designated as wilderness), are authorized to grant, issue, or renew rights-or-way over, upon, under, or through such lands for– (4) systems for generation, transmission, and distribution of electric energy, except that the applicant shall also comply with all applicable requirements of the Federal Energy Regulatory Commission under the Federal Power Act, including part I thereof (41 Stat. 1063, 16 U.S.C. 791a-825r) [P.L. 102-486, 1992]; and further in Sec. 504. [43 U.S.C. 1764] (a) The Secretary concerned shall specify the boundaries of each right-of-way as precisely as is practical. Each right-of-way shall be limited to the ground which the Secretary concerned determines (1) will be occupied by facilities which constitute the project for which the right- of-way is granted, issued, or renewed, (2) to be necessary for the operation or maintenance of the project, (3) to be necessary to protect the public safety, and (4) will do no unnecessary damage to the environment. The Secretary concerned may authorize the temporary use of such additional lands as he determines to be reasonably necessary for the construction, operation, maintenance, or termination of the project or a portion thereof, or for access thereto. To help streamline the comment review/implementation, I've attached a As indicated in the final Travel Management Rule, “Use of a road or 2488 file geodatabase (for use in GIS) which contains a feature class titled trail that is authorized by a legally documented right-of-way held by a "TravelManagementRoutes_AllAlternatives". We added an State, county, or other local public road authority” (36 CFR "APS_Comment" field in which we've delineated the aforementioned 212.51(a)(8)) is exempt from motor vehicle use. Under the authority of roads that we utilize for ongoing maintenance. For these select roads, the Federal Land Policy and Management Act of 1976 as amended we've noted "APS requires access". (P.L. 94-579) Sec. 501. [43 U.S.C. 1761] (a) The Secretary, with respect to the public lands (including public lands, as defined in section 103(e) of this Act, which are reserved from entry pursuant to section 24 of the Federal Power Act (16 U.S.C. 818)) [P.L. 102-486, 1992] and, the Secretary of Agriculture, with respect to lands within the National Forest System (except in each case land designated as wilderness), are authorized to grant, issue, or renew rights-or-way over, upon, under, or through such lands for– (4) systems for

153 Travel Management on the Tonto National Forest

Comment Letter Original Comment Text Forest Service Response Number generation, transmission, and distribution of electric energy, except that the applicant shall also comply with all applicable requirements of the Federal Energy Regulatory Commission under the Federal Power Act, including part I thereof (41 Stat. 1063, 16 U.S.C. 791a-825r) [P.L. 102-486, 1992]; and further in Sec. 504. [43 U.S.C. 1764] (a) The Secretary concerned shall specify the boundaries of each right-of-way as precisely as is practical. Each right-of-way shall be limited to the ground which the Secretary concerned determines (1) will be occupied by facilities which constitute the project for which the right- of-way is granted, issued, or renewed, (2) to be necessary for the operation or maintenance of the project, (3) to be necessary to protect the public safety, and (4) will do no unnecessary damage to the environment. The Secretary concerned may authorize the temporary use of such additional lands as he determines to be reasonably necessary for the construction, operation, maintenance, or termination of the project or a portion thereof, or for access thereto. The other major concern (in addition to the proposed decommissions) As indicated in the final Travel Management Rule, “Use of a road or 2488 is in regard to your verbiage prohibiting cross-country motorized travel. trail that is authorized by a legally documented right-of-way held by a If the intent is to restrict APS from being able to utilize our rights-of-way State, county, or other local public road authority” (36 CFR for cross-country access, this presents an enormous problem for APS 212.51(a)(8)) is exempt from motor vehicle use. Under the authority of as we're required to maintain said rights-of-way to mitigate for potential the Federal Land Policy and Management Act of 1976 as amended public safety hazards including preventing wildfires. APS has always (P.L. 94-579) Sec. 501. [43 U.S.C. 1761] (a) The Secretary, with utilized a combination of existing forest service roads AND our right-of- respect to the public lands (including public lands, as defined in way to access our structures for routine inspections, vegetation section 103(e) of this Act, which are reserved from entry pursuant to management, and critical line maintenance work. Unfortunately we do section 24 of the Federal Power Act (16 U.S.C. 818)) [P.L. 102-486, not have detailed data that identifies how each structure is accessed in 1992] and, the Secretary of Agriculture, with respect to lands within the field, as this is very dependent on existing ground conditions and the National Forest System (except in each case land designated as topography. If this preferred alternative is implemented, it is my hope wilderness), are authorized to grant, issue, or renew rights-or-way that TNF can grant APS a waiver and/or exemption from this over, upon, under, or through such lands for– (4) systems for stipulation. generation, transmission, and distribution of electric energy, except that the applicant shall also comply with all applicable requirements of the Federal Energy Regulatory Commission under the Federal Power Act, including part I thereof (41 Stat. 1063, 16 U.S.C. 791a-825r) [P.L. 102-486, 1992]; and further in Sec. 504. [43 U.S.C. 1764] (a) The Secretary concerned shall specify the boundaries of each right-of-way as precisely as is practical. Each right-of-way shall be limited to the ground which the Secretary concerned determines (1) will be

154 Volume II–Response to Comments

Comment Letter Original Comment Text Forest Service Response Number occupied by facilities which constitute the project for which the right- of-way is granted, issued, or renewed, (2) to be necessary for the operation or maintenance of the project, (3) to be necessary to protect the public safety, and (4) will do no unnecessary damage to the environment. The Secretary concerned may authorize the temporary use of such additional lands as he determines to be reasonably necessary for the construction, operation, maintenance, or termination of the project or a portion thereof, or for access thereto. SRP requests that the TNF recognize SRP's need to retain access to As indicated in the final Travel Management Rule, “Use of a road or 2489 infrastructure, including dams, reservoirs, easements, monitoring trail that is authorized by a legally documented right-of-way held by a gages, SNOTEL sites, microwave sites, power lines, substations, State, county, or other local public road authority” (36 CFR easements, and rights-of-way. 212.51(a)(8)) is exempt from motor vehicle use. Under the authority of the Federal Land Policy and Management Act of 1976 as amended (P.L. 94-579) Sec. 501. [43 U.S.C. 1761] (a) The Secretary, with respect to the public lands (including public lands, as defined in section 103(e) of this Act, which are reserved from entry pursuant to section 24 of the Federal Power Act (16 U.S.C. 818)) [P.L. 102-486, 1992] and, the Secretary of Agriculture, with respect to lands within the National Forest System (except in each case land designated as wilderness), are authorized to grant, issue, or renew rights-or-way over, upon, under, or through such lands for– (4) systems for generation, transmission, and distribution of electric energy, except that the applicant shall also comply with all applicable requirements of the Federal Energy Regulatory Commission under the Federal Power Act, including part I thereof (41 Stat. 1063, 16 U.S.C. 791a-825r) [P.L. 102-486, 1992]; and further in Sec. 504. [43 U.S.C. 1764] (a) The Secretary concerned shall specify the boundaries of each right-of-way as precisely as is practical. Each right-of-way shall be limited to the ground which the Secretary concerned determines (1) will be occupied by facilities which constitute the project for which the right- of-way is granted, issued, or renewed, (2) to be necessary for the operation or maintenance of the project, (3) to be necessary to protect the public safety, and (4) will do no unnecessary damage to the environment. The Secretary concerned may authorize the temporary use of such additional lands as he determines to be reasonably necessary for the construction, operation, maintenance, or termination of the project or a portion thereof, or for access thereto.

155 Travel Management on the Tonto National Forest

Comment Letter Original Comment Text Forest Service Response Number For each Alternative, we identified a number of routes that have been As indicated in the final Travel Management Rule, “Use of a road or 2489 proposed by the Forest Service for decommissioning. We are trail that is authorized by a legally documented right-of-way held by a requesting that these routes be retained under, at least, an 11 State, county, or other local public road authority” (36 CFR administrative access" designation to ensure SRP's ability to access 212.51(a)(8)) is exempt from motor vehicle use. Under the authority of infrastructure. The results of our review are provided in table format as the Federal Land Policy and Management Act of 1976 as amended an attachment to this letter (Attachment A). We are also providing this (P.L. 94-579) Sec. 501. [43 U.S.C. 1761] (a) The Secretary, with information as a GIS shapefile, highlighting the specific locations of respect to the public lands (including public lands, as defined in concern. section 103(e) of this Act, which are reserved from entry pursuant to section 24 of the Federal Power Act (16 U.S.C. 818)) [P.L. 102-486, 1992] and, the Secretary of Agriculture, with respect to lands within the National Forest System (except in each case land designated as wilderness), are authorized to grant, issue, or renew rights-or-way over, upon, under, or through such lands for– (4) systems for generation, transmission, and distribution of electric energy, except that the applicant shall also comply with all applicable requirements of the Federal Energy Regulatory Commission under the Federal Power Act, including part I thereof (41 Stat. 1063, 16 U.S.C. 791a-825r) [P.L. 102-486, 1992]; and further in Sec. 504. [43 U.S.C. 1764] (a) The Secretary concerned shall specify the boundaries of each right-of-way as precisely as is practical. Each right-of-way shall be limited to the ground which the Secretary concerned determines (1) will be occupied by facilities which constitute the project for which the right- of-way is granted, issued, or renewed, (2) to be necessary for the operation or maintenance of the project, (3) to be necessary to protect the public safety, and (4) will do no unnecessary damage to the environment. The Secretary concerned may authorize the temporary use of such additional lands as he determines to be reasonably necessary for the construction, operation, maintenance, or termination of the project or a portion thereof, or for access thereto.

156 Volume II–Response to Comments

Public Involvement Comment Letter Original Comment Text Forest Service Response Number We would greatly appreciate presenting our comment package to TNF On July 22, 2014, representatives from Arizona Off Highway Vehicle 2518 staff to make sure there is no misunderstanding and that our Coalition and AZ Trail Riders and Tonto Recreation Alliance met with comments are understood. Please let us know when we could meet Forest Service employees at the Supervisor's Office, and included staff with staff to go thru our comments. from the Mesa and Cave Creek ranger districts, including both district rangers. The issues and concerns raised by these groups were discussed at this time. Their input and proposals for a motor vehicle system were further discussed with district employees, including resource specialists and district rangers, for proposed inclusion in the final designation after the comment period closed. Yet, the proposed plan has failed to address specific comments Comment is an opinion and lacks "supporting reasons for the 1716 previously submitted in 2012. responsible official to consider" per 36 CFR 218.2. No further response warranted. A more complete response to previously submitted comments should Per 40 CFR 1503.4(a), "An agency preparing a final environmental 1716 be made by your agency. impact statement shall assess and consider comments both individually and collectively, and shall respond by one or more of the means listed below, stating its response in the final statement." Comments not related to the draft EIS have been reviewed and were used to identify issues that drove the creation of alternatives per § 1501.7(a). On your web site links you list approximately 200 comments received. All comment letters can be found in the project record, located at the 1716 A review of those comments appears to show that you have only listed Supervisor's Office in Phoenix, Arizona. Project management software those comments received during the initial 30 day comment period has been used intermittently throughout the life of this project, resulting (later extended). No on line comments could be found (including mine) in some letters being available electronically and others only available that you received after the initial short 30 day period. Where are those in the project record. Per 40 CFR 1501.7(a), comments received comments and why were they not addressed in your proposal? outside of the comment period on a draft EIS are considered and used to identify issues with the proposed action, which in turn, may have led to the development of an alternative. As indicated in the notice of intent to prepare an environmental impact statement that was posted to the Federal Register on February 1, 2013, "All comments provided throughout the process thus far, including those to the 2009 proposed action, the 2012 Environmental Assessment, and public meetings, will continue to be considered and may be incorporated into either the proposed action for the EIS or alternatives to that proposed action."

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Comment Letter Original Comment Text Forest Service Response Number Your proposal fails to address your thought process as to why specific Per 40 CFR 1501.7(a), comments received outside of the comment 1716 comments were adopted or not. period on a draft EIS are considered and used to identify issues with the proposed action, which in turn maybe lead to the development of an alternative. As indicated in the notice of intent to prepare an environmental impact statement that was posted to the Federal Register on February 1, 2013, "All comments provided throughout the process thus far, including those to the 2009 proposed action, the 2012 Environmental Assessment, and public meetings, will continue to be considered and may be incorporated into either the proposed action for the EIS or alternatives to that proposed action." I read several comments from others which asked that specific routes Per 40 CFR 1503.4(a), "An agency preparing a final environmental 1716 (by route number and location) be included or omitted. Your plans fails impact statement shall assess and consider comments both to mention why such and such a route was added or deleted. With individually and collectively, and shall respond by one or more of the such a long period of time to work on this project and with the means listed below, stating its response in the final statement." extensive analysis done, why not complete the process by addressing Comments not related to the draft EIS have been reviewed and were these comments? used to identify issues that drove the creation of alternatives per § 1501.7(a). Responses to specific routes submitted during the draft EIS comment period can be found in this table in the corresponding section. As I only have one day, Sept 17, 2014 to comment on the closure of As detailed in the “Public Involvement” section of chapter 1 of the final 2493 traveled roads in the Tonto National Forest, I can't say exactly what I EIS, a notice of intent to prepare an EIS was published in the Federal am protesting because the issues are so clouded, the language is Register, initiating a 30-day scoping period on the proposed action. evasive, maps are too small to read, and no one seems to know the Approximately 1,794 postcards and 1,673 emails were sent to exact nature of the closures, who to contact, or anything else. I submit, interested and affected parties. On July 3, 2014, a notice of availability there was not enough public notification, local personnel do not know of the draft EIS was published in the Federal Register, initiating the 45- when, or how this notification was published concerning these day comment period, which was extended an additional 30 days. changes. Nearly 7,000 postcards and approximately 1,350 emails were sent out notifying of the comment period. Additionally, all of the up-to-date project information can be found electronically at: http://www.fs.usda.gov/detail/tonto/landmanagement/planning/?cid=fsb dev3_018761 or http://data.ecosystem-management.org/nepaweb/fs- usda-pop.php?project=28967. Electronic information was updated regularly on these websites during the 75-day comment period for the draft EIS. There is a 3 inch thick book outlining all these new changes in our The draft EIS and its supporting reports were available electronically 2493 forest service office which cannot leave the building. The language is at:

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Comment Letter Original Comment Text Forest Service Response Number not written to be understood by a regular citizen, the maps are so small http://www.fs.usda.gov/detail/tonto/landmanagement/planning/?cid=fsb you can't read them, and even if you can read them, you can't dev3_018761 or http://data.ecosystem-management.org/nepaweb/fs- correspond them to the changes the fs is making. usda-pop.php?project=28967. Additionally, hard copies of project documents, maps, and other forms of the information (including CDs with the information) were sent out immediately to anyone that made the request to the project leader, Anne Thomas, and other Forest Service employees when necessary. Provide written responses in a preamble or other publication when the This appendix and table serves to comply with 40 CFR 1503.4(a) and 1716 final plan is made. fulfills this commenter's request. *WE NEED COMMUNICATION AND TRANSPARENCY WITH Comment lacks "supporting reasons for the responsible official to 1983 GOVERNMENT ENTITIES - please listen to us, meet with us and consider" per 36 CFR 218.2. No further response warranted. support our position. The TNF should disclose any plans or ideas it is considering to involve This information has been identified in the draft implementation 2471 outside participants, including city and county agencies, public strategy that can be found at: http://data.ecosystem- organizations, or specific user groups, to assist in general management.org/nepaweb/fs-usda-pop.php?project=28967 or in the maintenance. If the Forest Service has not identified any opportunities project record. It is the hope of the Forest Service that once the travel to involve other groups in maintenance activities, it should at least management decision is signed and ready to be implemented, highlight the possibility of such collaboration and include it as a additional partnership and collaborations will be developed. component of the final travel management plan. For the most part our comments are very specific to individual routes, On July 22, 2014, representatives from Arizona Off Highway Vehicle 2510 relationships between routes and types of use. In order for the Tonto to Coalition and AZ Trail Riders and Tonto Recreation Alliance met with come to a complete understanding of the comments to enable Forest Service employees at the Supervisor's Office, and included staff informed decisions we are requesting face-to-face review meetings from the Mesa and Cave Creek ranger districts, including both district with the forest decision makers prior to a final decision. rangers. The issues and concerns raised by these groups were discussed at this time. Their input and proposals for a motor vehicle system were further discussed with district employees, including resource specialists and district rangers, for proposed inclusion in the final designation after the comment period closed. The Tonto is a very large forest and more time would be requested to On July 3, 2014, a notice of availability of the draft EIS was published 4 complete the entire review. The ASA4WDC members and board would in the Federal Register, initiating the 45-day comment period, which request that the Tonto National Forest extend the comment period on was extended an additional 30 days. The comment period for the draft the travel plan for at least 60 days. EIS was a total of 75 calendar days. The Tonto National Forest believes that this was adequate time for review, considering how many times this project has been released to the public for input, including when the environmental assessment was prepared.

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Comment Letter Original Comment Text Forest Service Response Number The ASA4WDC supports the comments, documents and maps that In the commenter's letter, they outline specific recommendations which 4 have been submitted by the Arizona Off Highway Vehicle Coalition are addressed in the “Route Specific” section of this table. (AZOHVC). Our members have worked alongside the AZOHVC staff on popular OHV routes and areas in the Tonto. I am very interested in how this moves forward and what actions may Once a draft record of decision and the final EIS is made available, a 6 be taken in the Tonto National Park Area, if you could keep me notification in the Federal Register (the notice of availability of the final informed of any further actions it would be greatly appreciated. EIS) and the paper of record (for the draft record of decision which begins the predecisional review process) will be posted. Additionally, notification will either be mailed or emailed to those that have commented on this project or are on the mailing list. The information will also be posted to the following website: http://data.ecosystem- management.org/nepaweb/fs-usda-pop.php?project=28967 and made available at Supervisor's Office and district offices. How do we make comments on the plan? On July 3, 2014, a notice of availability of the draft EIS was published 23 in the Federal Register, initiating the 45-day comment period, which was extended an additional 30 days. Comments on the draft EIS are no longer being accepted for consideration for travel management. Once the final EIS and draft decision are posted, those that meet the requirements laid out in 36 CFR 218 can provide additional input in the form of an objection to the draft decision. The Tonto National Forest always welcomes input and feedback from the public. However, as part of the NEPA process, there are required times—during any designated opportunity for public comment that commenters may file an objection (36 CFR 218.5(2))—-when comments submitted will be considered for the project. Please send me a response on ur plan on this or let me k ow how you This appendix and table serves to comply with 40 CFR 1503.4(a) and 2082 feel about the idea. fulfills this commenter's request. I was wondering if you would be able to direct me to specific areas of Maps were made available at Tonto National Forest offices and 2366 http://data.ecosystem-management.org/nepaweb/fs-usda- electronically for the four alternatives being analyzed that addressed pop.php?project=28967 that would cover our section of interest: this commenter's concerns. Goldfield Ranch on South side of Rt. 87: around base of Mount Stewart, between Bush Highway, Rt. 87 and Salt River. Would like to be notified so we may attend TMP meetings to keep At this time, no meetings specific to travel management on the Tonto 2500 residents and equestrians informed and assist with input. Please send National Forest are planned. Once a draft record of decision and the information. final EIS is made available, a notification in the Federal Register (the

160 Volume II–Response to Comments

Comment Letter Original Comment Text Forest Service Response Number notice of availability of the final EIS) and the paper of record (for the draft record of decision which begins the predecisional review process) will be posted. Additionally, notification will either be mailed or emailed to those that have commented on this project or are on the mailing list. The information will also be posted to the following website: http://data.ecosystem-management.org/nepaweb/fs-usda- pop.php?project=28967 and made available at Supervisor's Office and district offices. We appreciate the opportunity to review this DEIS. Please send one Once a draft record of decision and the final EIS is made available, a 2504 hard copy of the FEIS and one CD to the address above (mail code: notification in the Federal Register (the notice of availability of the final ENF 4-2). EIS) and the paper of record (for the draft record of decision which begins the predecisional review process) will be posted. Additionally, notification will either be mailed or emailed to those that have commented on this project or are on the mailing list. The information will also be posted to the following website: http://data.ecosystem- management.org/nepaweb/fs-usda-pop.php?project=28967 and made available at Supervisor's Office and district offices. Ranger District offices should be open on weekends during summer to This requests is outside the scope of the decisions being considered 1983 visitors and forest employees and volunteers to monitor activity in for this project. This information will be passed on to the specific ranger Tonto forest district, as appropriate, for further consideration. Ranger District offices should be open on weekends during summer to This requests is outside the scope of the decisions being considered 2500 visitors and forest employees and volunteers to monitor activity in for this project. This information will be passed on to the specific ranger Tonto forest district, as appropriate, for further consideration.

161 Travel Management on the Tonto National Forest

General Analysis Comment Letter Original Comment Text Forest Service Response Number We recommend expanding the analyses to further discuss the The assessment for Travel Management on the Tonto National Forest 2503 addition/deletion of motorized road miles, the total number of roads by is being conducted on a Forestwide scale. The Game and Nongame type that will be authorized, and total areas impacted by cross-country Species report details where hunting units are related to forest ranger travel by district. Specifically, we recommend discussing how Payson districts. All resource specialists analyzed the effects to their resource and Pleasant Valley Ranger Districts will be affected by the proposed from motor vehicle use for big game retrieval and dispersed camping, changes versus how Cave Creek, Globe, Mesa, and Tonto Basin along with designated OHV areas at a scope and scale that is Ranger Districts will be affected by the allowance of motorized big appropriate for their resource. All of this information can be found in game retrieval and motor vehicle use off-road for other purposes. chapter 3 of the final EIS. Table 72 on page 466 lists route miles and route density by Ranger District, and perhaps additional specifics can be added to better describe how the proposed changes would affect natural resources. Based on our review, we have rated the DEIS as Environmental In the EPA's letter, they identified specific areas where the analysis 2504 Concerns- Insufficient Information (EC-2) (see enclosed "Summary of and the draft EIS needed further explanation or clarification. These Rating Definitions"). In our attached Detailed Comments, we describe specific points and their responses can be found in the following in greater depth our concerns and our recommendations for sections of this table: “Air Quality,” “Transportation,” and “Hydrological addressing these matters. Resources.” Chapter 2 of the FEIS should describe the actions that would be taken Actions associated with the implementation of a designated motor 2504 to implement the project. These actions might include placement of vehicle system on the Tonto National Forest can be found in chapter 2, physical barriers at key locations, rider education programs, increased under the description of alternative B, where there is more information patrol of newly closed areas, and mitigation activities on newly about implementing administrative use only routes and authorized routes. decommissioning routes. Information about the implementation of a designated road system can be found in the Transportation Facilities report and the motorized trail draft implementation strategy, both of which can be found at http://data.ecosystem- management.org/nepaweb/fs-usda-pop.php?project=28967 or in the project record at the Supervisor's Office in Phoenix, Arizona. The Department appreciates the opportunity to assist in the In the Department's letter, they outline specific recommendations 2497 development of the DEIS. It is the policy of the Arizona Game and Fish which are addressed in the following sections of this table: “Law Commission to place high emphasis on multiple uses of public lands Enforcement,” “Game and Nongame Species,” “Route Specific,” and including the conservation of existing access for wildlife related “Recreation.” recreation. It is the mission of the Department to conserve Arizona's diverse wildlife resources and manage for safe, compatible, outdoor recreation opportunities for current and future generations. The Department's requests within this letter provide for a proposed

162 Volume II–Response to Comments

Comment Letter Original Comment Text Forest Service Response Number alternative that assists the Department in fulfilling its state trust responsibilities for fish and wildlife resources. Sadly, we believe much of the Forest Service's management of the Comment is an opinion and lacks "supporting reasons for the 29 TNF can be characterized as neglectful. Over the twelve years we responsible official to consider" per 36 CFR 218.2. No further have lived in the area, we have seen both more intense and response warranted. widespread destruction of the desert and forested areas of TNF. Your numbers just do not add up. If you combined the number of miles As detailed in chapters 1 and 2 of the final EIS, the existing condition 29 of roads that would be kept with the number of miles of roads that for roads for this analysis is approximately 4,959 miles. In addition, would be de-commissioned under the various alternatives, you get a there are nearly 740 miles of unauthorized routes for which the Forest sum of 3,261 miles for Alternative B, 2,630 for Alternative C, and 3,541 has GIS data. The final Travel Management Rule permits for the for Alternative D. How can this be? This makes no sense since the designation of motorized trails, which is one of the issues that the number of miles of existing roads plus de-commissioned roads should public has raised. For each alternative, depending on the issues that it be the same for all three alternatives. In addition, it makes no sense responds to, there is the option to decommission roads that currently that Alternative C appears to have fewer miles of roads than exist, reclassify the route as a motorized trail, or add miles to the Alternative B. The number of miles of roads that currently exist, plus system that are unauthorized. Each alternative has a spreadsheet of the number of miles of roads that are de-commissioned, should be the every route from the existing condition (including the unauthorized same for all three alternatives. routes) and a detailed description of what it becomes for that alternative. This information can be found in the project record. We request consideration of an additional, separate alternative limited The consideration of the alternative being requested was done and can 2471 to documented routes as described above in a supplemental DEIS. We be found in chapter 2, in the section “Alternatives Considered but further request that the agency compare proposed route additions to Eliminated from Detailed Study” in the final EIS, which includes a full our limited to open system routes alternative and baseline as it will rationale for why it was eliminated from further consideration. provide a much more accurate picture of ongoing impacts related to motorized recreation and allows for a true analysis of the impacts of the proposed alternatives. I recommend adding the total road density of each alternative to Table This information can be found at the end of chapter 2 of the final EIS, 2498 14, Side-by-Side Comparison of Alternatives (page 61). I also think in the table "Comparison of Effects for Alternatives by Resources" for decision-makers and the public would benefit from a clearer resources that used this measurement in their analysis. Road density comparison of alternatives based on target road density ratios for is one of many metrics used in comparing the alternatives and is not discrete resources. appropriate for the "side-by-side comparison of alternatives" table. Access is an important variable because it influences safety, ease of Comment is an opinion and lacks "supporting reasons for the 2498 entry, trespass, resource degradation, and user satisfaction, among responsible official to consider" per 36 CFR 218.2. No further other factors. response warranted.

163 Travel Management on the Tonto National Forest

Comment Letter Original Comment Text Forest Service Response Number There is one more metric I would recommend adding to the Without understanding what this metric is meant to represent or what 2498 comparison of alternatives: the number of access points into the Forest value it would possess when comparing the alternatives, this comment for each alternative. lacks "supporting reasons for the responsible official to consider" per 36 CFR 218.2. No further response warranted. When giving consideration to potential impacts associated with the This information is detailed in chapter 3 of the final EIS by resource 2503 implementation of Alternative C it is difficult to interpret and understand area. how the proposed 3,569.52 total miles of roads to be open to the public would be beneficial compared to the No Action Alternative. Since off-road travel is currently restricted in the Cave Creek, Globe, Without this type of data, the Tonto is unable to provide the requested 2503 Mesa, and Tonto Basin Ranger Districts, but unrestricted travel is analysis. There have been no scientific studies on the Tonto to show authorized in Payson and Pleasant Valley districts, it would be more users patterns for dispersed camping or big game retrieval anywhere meaningful to discuss potential areas where hunters and campers are within the Forest. likely to travel off-road for big game retrieval and dispersed camping in each of the Ranger Districts or identify areas previously used for cross- county travel that would now be closed under Alternative C The TNF should develop additional alternatives that present a greater Comment is an opinion and lacks "supporting reasons for the 2471 range of options that respond to key issues, such as appropriate responsible official to consider" per 36 CFR 218.2. However, the motorized big game retrieval corridors, enforcement approaches and Tonto National Forest has developed a range of alternatives (chapter 2 planning, and a minimal route system that would meet the purpose and of the final EIS) that address issues identified from scoping (more needs for this project. While the development and presentation of information about these issues can be found in chapter 1 of the final these alternatives may add additional time to complete this project, it is EIS) and without further specific information, this comment will warrant necessary for compliance with NEPA and to ensure the final result no further response. adequately responds to public input and comment. Service should choose the alternative that encourages, rather than Comment is an opinion and lacks "supporting reasons for the 2502 discourages the public from using its national forests for wildlife- responsible official to consider" per 36 CFR 218.2. No further oriented recreational activities. response warranted. I would like for the forest service to clarify the 1 mile off-road motorized Information regarding the limitations associated with big game retrieval 31 exception rule for hunting (C, D). I have witnessed hunters can be found in chapter 2 of the final EIS, under the alternatives, constructing trails in the forest *prior* to their hunting period. Please subheading "Motor Vehicle Use for Big Game Retrieval." This make sure that if option C or D are adopted (my choice would be "B"), information addresses all the commenter's concerns. that it is clear that hunters can only use motorized vehicles on pre- existing decommissioned off road trails to collect their game, and that "renovations" on decommissioned trails for hunting purposes is not permitted.

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Comment Letter Original Comment Text Forest Service Response Number Authorize dispersed motorized collection of firewood. The authorized As indicated in the draft record of decision, motor vehicle use for 2512 motorized collection of firewood consists of the minimum number of personal fuelwood gathering will be permitted within designated trips each way, as defined based on the transport capacity of the fuelwood areas with the following stipulations (as outlined on the vehicle and the trailer, from the downed tree to the closest legally open permit and accompanying paperwork): (1) Locate fuelwood before road or trail, regardless of distance, in the authorized firewood moving vehicle off route; take the most direct route to the product; (2) collection area, by the most direct route compatible with safety and the Do not damage other vegetation in route to product location; (3) Return preservation of other values such as riparian areas, archeological to the designated road on the same direct path used; cover your route sites, etc. with slash or other available debris; (4) If there is no good route; do not attempt to collect that fuelwood; and (5) Do not go off road when soils are wet or rutting may occur. Firewood gathered in the Tonto National Forest is an important and As indicated in the draft record of decision, motor vehicle use for 2512 necessary energy resource to many residents of Gila County. Gila personal fuelwood gathering will be permitted within designated County therefore recommends that motorized access be allowed for fuelwood areas with the following stipulations (as outlined on the the purpose of firewood gathering in areas specifically designated for permit and accompanying paperwork): (1) Locate fuelwood before motorized firewood gathering, or that the authorized motorized moving vehicle off route; take the most direct route to the product; (2) collection of firewood consist of the minimum number of trips each Do not damage other vegetation in route to product location; (3) Return way, as defined based on the transport capacity of the vehicle and the to the designated road on the same direct path used; cover your route trailer, from the downed tree to the closest legally open road or trail in with slash or other available debris; (4) If there is no good route; do not the authorized firewood collection area, by the most direct route attempt to collect that fuelwood; and (5) Do not go off road when soils compatible with safety and the preservation of other values such as are wet or rutting may occur. riparian areas, archeological sites, etc. It must also be realized that closing (or downgrading status, which has Comment is an opinion and lacks "supporting reasons for the 554 the same effect) all of these roads will severely impact access in case responsible official to consider" per 36 CFR 218.2. Furthermore, of fire suppression. A common meme heard in every major forest fire is district fire management staff were included in the creation of the officials bemoaning lack of access in time of such need. preferred alternative, alternative C. The Forest Service has a responsibility to analyze and discuss the Comment is an opinion and lacks "supporting reasons for the 2471 impacts associated with reclassification of roads, especially when that responsible official to consider" per 36 CFR 218.2 outside of the above reclassification and mapping will result in significantly more use and submitted comments which have been specifically responded to. No need for maintenance. The TNF’s assumption that it need not analyze further response warranted. impacts from closed or decommissioned routes because it has taken improperly included them in the official open route system is baseless and in violation of both the intent and requirements of NEPA. The TNF should provide a rational explanation for dismissing the entire The decision to not use information from the previous Travel Analysis 2471 TAP (or TAPs) and previously identified MRS. Process (TAP) and subsequent minimum road system identified that was conducted for preparation of the environmental analysis is detailed

165 Travel Management on the Tonto National Forest

Comment Letter Original Comment Text Forest Service Response Number in chapter 2 of the final EIS, in the section “Alternatives Considered but Eliminated from Detailed Study.” As indicated in the previously released environmental assessment (January 2012), the TAP was used to create the original proposed action scoped in 2009. In preparation of this EIS, the TAP was reviewed. In terms of the TAP, what exists in the current project record for each specific route on the forest lacks detailed information about the potential effects of each route on resources in terms of context and intensity. Since “The NEPA process is intended to help public officials make decisions that are based on understanding of environmental consequences…” (40 CFR 1500.1(c)) and Federal agencies are required to make conclusions that are not arbitrary or capricious as required by the Administrative Procedures Act of 1946, the existing information related to the TAP was found to be lacking these statutory requirements and it was determined that the existing information in the TAP would not provide a solid rationale for the decision to designate a motorized route system. The TNF should provide a route-by-route analysis of the existing and Nowhere in 36 CFR 218 Subpart B--Designation of Roads, Trails, and 2471 proposed designated system for all alternatives that identifies the risks Areas for Motor Vehicle Use--does it require that the risks and benefits and benefits of each route. The rationale for including any High of a proposed route be considered when complying with the Travel Risk/Low Benefit route must be provided. In light of extreme budget Management Rule. Instead, §212.55(a) indicates that, " the constraints and excessive route densities on the ground, the rationale responsible official shall consider effects on National Forest System for including any user-created route must be provided. natural and cultural resources, public safety, provision of recreational opportunities, access needs, conflicts among uses of National Forest System lands, the need for maintenance and administration of roads, trails, and areas that would arise if the uses under consideration are designated; and the availability of resources for that maintenance and administration." The process that the Tonto National Forest is using through this NEPA process complies with the rule as stipulated the above mentioned regulations. The TNF should provide documentation of the route by route analysis As outlined in appendix A of the Transportation report, an initial 2471 alleged at page 71 of the DEIS. examination of the road system found in Infra was conducted from the perspective of engineering needs. Once this was done, resource specialists, along with Forest Service law enforcement personal and Arizona Game and Fish Department wildlife managers reviewed the system to determine what would be the modified proposed action based on on-the-ground knowledge of the route and current resource

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Comment Letter Original Comment Text Forest Service Response Number conditions. Detailed accounts of this process can be found in the project record in the Supervisor's Office in Phoenix, Arizona. Given the following statement in the DEIS, please explain what As outlined in appendix A of the transportation report, an initial 2471 documents were used for the development of the proposed designated examination of the road system round in Infra was conducted from the route system in 2013. As part of the process in complying with the final perspective of engineering needs. Once this was done, resource travel management regulations, the Tonto National Forest conducted a specialists, along with Forest Service law enforcement personal and forestwide travel analysis process in 2006, reviewing the entire current Arizona Game and Fish Department wildlife managers reviewed the road system. The intent of this process was to identify needed system to determine what would be the modified proposed action changes to the existing road and motorized trail systems. In early based on on-the-ground knowledge of the route and current resource 2013, with the development of an environmental impact statement to conditions. Detailed accounts of this process can be found in the analyze the effects of implementing the travel management rule, forest project record in the Supervisor's Office in Phoenix, Arizona. staff reviewed and refined the proposed designated road and motorized trail system to ensure protection, while providing for administration and utilization, of National Forest System lands (36 CFR 212.5(b)).” Additionally, if the proposed designated route system was developed The decision to not use information from the previous Travel Analysis 2471 utilizing the TAP from 2006, please provide a rational basis for now Process (TAP) that was conducted for preparation of the completely discarding the TAP. environmental assessment is detailed in chapter 2 of the final EIS, in the section “Alternatives Considered but Eliminated from Detailed Study.” As indicated in the previously released environmental assessment (January 2012), the TAP was used to create the original proposed action scoped in 2009. In preparation of this EIS, the TAP was reviewed. In terms of the TAP, what exists in the current project record for each specific route on the Forest lacks detailed information about the potential effects of each route on resources in terms of context and intensity. Since “The NEPA process is intended to help public officials make decisions that are based on understanding of environmental consequences…” (40 CFR 1500.1(c)) and federal agencies are required to make conclusions that are not arbitrary or capricious as required by the Administrative Procedures Act of 1946, the existing information related to the TAP was found to be lacking these statutory requirements and it was determined that the existing information in the TAP would not provide a solid rationale for the decision to designate a motorized route system. Route designations, including use of the Route Evaluation Tree, must It is unclear what the "Route Evaluation Tree" is that the commenter is 2471 reflect adherence to the minimization criteria found in the Executive referring to. The decision to not use information from the previous

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Comment Letter Original Comment Text Forest Service Response Number Orders and Subpart B of the TMR. Moreover, the record must reflect Travel Analysis Process—conducted for preparation of the EA—is that each route designation complies with these requirements. detailed in chapter 2 of the final EIS in the section “Alternatives Considered but Eliminated from Detailed Study.” All documentation for how the Tonto reviewed and consider the designated motor vehicle route system can be found in the project record in the Supervisor's Office in Phoenix, Arizona. We again specifically request the Forest Service to provide to us the It is unclear what the "Route Evaluation Tree" is that the commenter is 2471 route evaluation forms and any other information on the Route referring to. The decision to not use information from the previous Evaluation Tree that would inform the public on what criteria were used Travel Analysis Process—conducted for preparation of the EA—is for route designation decisions, how those criteria were weighted, and detailed in chapter 2 of the final EIS in the section “Alternatives how the Route Evaluation Tree was applied to each route. Considered but Eliminated from Detailed Study.” All documentation for how the Tonto reviewed and consider the designated motor vehicle route system can be found in the project record in the Supervisor's Office in Phoenix, Arizona. Having detailed knowledge of on-the-ground conditions we know that Without GIS specific data (including longitude, latitude, and length) of 2405 there are hundreds of miles of roads that are not in the Forest’s data these routes, the Forest Service cannot analyze them. When the travel base. Many of the roads not in the data base are as good if not better management decision is signed and implemented, it is the beginning of than the roads that are included in the data base. The fact that every creating a motor vehicle system for the Tonto National Forest. Many of one of these roads will be closed because they will fall into the "cross these routes, once the GIS data have been collected, can be country" category needs to be explained in greater detail in the FEIS. considered for addition to the designation through additional NEPA analysis. The USFS must analyze the effect of reducing road densities and Route density is one of many metrics that can display the differences 2521 consider that mitigation when prescribing reductions in reduced between alternatives and is one of many considerations that the Forest camping opportunities. If the USFS can meet management objectives Supervisor, as the deciding official for this project, took into through reduced road densities and campsite designation, dispersed consideration when determining the future of the motor vehicle use on camping opportunities should be retained. the Tonto National Forest. In chapter 3 of the final EIS, both the “Wildlife Habitat Resources” and “Hydrology Resources” sections analyzes the effects of route density on the natural resources. In addition, the draft record of decision indicates that motorized access for dispersed camping will be via designated spur motorized trails for full-sized four-by-four vehicles. If road densities are maintained below a threshold of at least one mile Route density is one of many metrics that can display the differences 2521 of road per two square miles of unroaded area, limited, designated between alternatives and is one of many considerations that the Forest dispersed campsites will maintain a quality backcountry experience Supervisor, as the deciding official for this project, took into and minimize disturbance to wildlife. The USFS should maintain consideration when determining the future of the motor vehicle use on the Tonto National Forest. In chapter 3 of the final EIS, both the

168 Volume II–Response to Comments

Comment Letter Original Comment Text Forest Service Response Number dispersed camping opportunities and mitigate these impacts through “Wildlife Habitat Resources” and “Hydrology Resources” sections reduction of road densities and campsite designation. analyzes the effects of route density on the natural resources.

169 Travel Management on the Tonto National Forest

Purpose and Need Comment Letter Original Comment Text Forest Service Response Number The TNF must accurately characterize the need for this action, the The purpose of and need for this project includes "The purpose of this 2471 problems with current management, and the existing and desired project is to comply with the Travel Management Rule by providing a conditions to take into account the requirements of executive orders system of roads, trails, and areas designated for motor vehicle use by 11644 and 11989 and the TMR as they relate to the reasons for travel class of vehicle and time of year on the Tonto National Forest" (chapter management and the objectives for this action. 1 of the final EIS), which satisfies the commenter’s request in its entirety. Furthermore, as stipulated in the final Travel Management Rule, “Executive orders issued by the President of the United States provide policy direction to all Federal agencies. The Department conforms its policy to executive orders and believes that it is appropriate to take applicable executive orders, such as E.O. 11644 and E.O. 11989, into account in promulgating regulations and issuing directives” and “The general criteria of [36 CFR] § 212.55(a) and the specific criteria of § 212.55(b) are taken directly from E.O. 11644. The E.O. applies only to trails and areas designated for motor vehicle use. However, the Department believes that the general criteria cited in the Executive order are of such universal applicability that they should be considered in designating roads, as well as trails and areas” (Federal Register, Volume 70, Number 216, pages 68272 and 68281) and in travel management related courts cases (i.e., Central Sierra Environmental Resources Center, et al. v. United States Forest Service, et al., 01/023/2013 and Idaho Conservation League and the Wilderness Society v. Guzman and U.S. Forest Service, 2/4/2011), compliance with the Travel Management Rule complies with Executive Orders 11644 and 11989. In addition, issues related to these suggestions are outlined in chapter 1, alternatives were developed to address these issues (chapter 2), and much of the route development on the Tonto and the effects analysis found in chapter 3 address the effects of the commenter’s suggestions. All of this information can be found in the project record located at the Supervisor's Office in Phoenix, Arizona. The TNF must redefine the purpose of this action to include this The purpose of and need for this project includes "The purpose of this 2471 direction or a similar statement, to ensure that the travel management project is to comply with the Travel Management Rule by providing a planning process and final travel management plan is consistent with system of roads, trails, and areas designated for motor vehicle use by the intent of the executive orders. class of vehicle and time of year on the Tonto National Forest" (chapter 1 of the final EIS), which satisfies the commenter’s request in its

170 Volume II–Response to Comments

Comment Letter Original Comment Text Forest Service Response Number entirety. Furthermore, as stipulated in the final Travel Management Rule, “Executive orders issued by the President of the United States provide policy direction to all Federal agencies. The Department conforms its policy to executive orders and believes that it is appropriate to take applicable executive orders, such as E.O. 11644 and E.O. 11989, into account in promulgating regulations and issuing directives” and “The general criteria of [36 CFR] § 212.55(a) and the specific criteria of § 212.55(b) are taken directly from E.O. 11644. The Executive order applies only to trails and areas designated for motor vehicle use. However, the Department believes that the general criteria cited in the Executive order are of such universal applicability that they should be considered in designating roads, as well as trails and areas” (Federal Register, Volume 70, Number 216, pages 68272 and 68281) and in travel management related courts cases (i.e., Central Sierra Environmental Resources Center, et al. v. United States Forest Service, et al., 01/023/2013 and Idaho Conservation League and the Wilderness Society v. Guzman and U.S. Forest Service, 2/4/2011), compliance with the Travel Management Rule complies with Executive Orders 11644 and 11989. In addition, issues related to these suggestions are outlined in chapter 1, alternatives were developed to address these issues (chapter 2), and much of the route development on the Tonto and the effects analysis found in chapter 3 address the effects of the commenter’s suggestions. All of this information can be found in the project record located at the Supervisor's Office in Phoenix, Arizona. The TNF should acknowledge the following additional needs for this The purpose of and need for this project includes "The purpose of this 2471 project, which will further clarify the necessity of this action and the project is to comply with the Travel Management Rule by providing a constraints on the Forest Service’s final decision: The need to identify system of roads, trails, and areas designated for motor vehicle use by a route system that minimizes damages to natural and cultural class of vehicle and time of year on the Tonto National Forest" (chapter resources on the Tonto National Forest. The need to prohibit motor 1 of the final EIS), which satisfies the commenter’s request in its vehicle use off the system of designated roads, trails, and areas, entirety. The final Travel Management Rule requires “…the responsible thereby eliminating cross-country travel except in designated areas, official shall consider effects on the following, with the objective of consistent with the Travel Management Rule (36 C.F.R § 261.13). minimizing: (1) Damage to soil, watershed, vegetation, and other The need to minimize conflict between motorized and non-motorized Forest resources; (2) Harassment of wildlife and significant disruption forest users. of wildlife habitats; (3) Conflicts between motor vehicle use and existing or proposed recreational uses of National Forest System lands or neighboring Federal lands; and (4) Conflicts among different classes

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Comment Letter Original Comment Text Forest Service Response Number of motor vehicle uses of National Forest System lands or neighboring Federal lands” (36 CFR 212.55(b)). In addition, “An extreme interpretation of ‘‘minimize’’ would preclude any use at all, since impacts always can be reduced further by preventing them altogether. Such an interpretation would not reflect the full context of E.O. 11644 or other laws and policies related to multiple use of National Forest System lands …The Department believes ‘shall consider * * * with the objective of minimizing* * *’will assure that environmental impacts are properly taken into account, without categorically precluding motor vehicle use” (Federal Register, Volume 70, Number 216, page 68281). The TNF should acknowledge the following additional needs for this The purpose of and need for this project includes "The purpose of this 2471 project, which will further clarify the necessity of this action and the project is to comply with the Travel Management Rule by providing a constraints on the Forest Service’s final decision: • The need to system of roads, trails, and areas designated for motor vehicle use by identify a route system that minimizes damages to natural and cultural class of vehicle and time of year on the Tonto National Forest" (chapter resources on the Tonto National Forest. The need to prohibit motor 1 of the final EIS), which satisfies the commenter’s request in its vehicle use off the system of designated roads, trails, and areas, entirety. The final Travel Management Rule requires “…the responsible thereby eliminating cross-country travel except in designated areas, official shall consider effects on the following, with the objective of consistent with the Travel Management Rule (36 C.F.R § 261.13). minimizing: (1) Damage to soil, watershed, vegetation, and other forest The need to minimize conflict between motorized and non-motorized resources; (2) Harassment of wildlife and significant disruption of forest users. wildlife habitats; (3) Conflicts between motor vehicle use and existing or proposed recreational uses of National Forest System lands or neighboring Federal lands; and (4) Conflicts among different classes of motor vehicle uses of National Forest System lands or neighboring Federal lands” (36 CFR 212.55(b)). In addition, “An extreme interpretation of ‘‘minimize’’ would preclude any use at all, since impacts always can be reduced further by preventing them altogether. Such an interpretation would not reflect the full context of E.O. 11644 or other laws and policies related to multiple use of National Forest System lands …The Department believes ‘shall consider * * * with the objective of minimizing* * *’will assure that environmental impacts are properly taken into account, without categorically precluding motor vehicle use” (Federal Register, Volume 70, Number 216, page 68281).

172 Volume II–Response to Comments

Specific Alternatives Comment Letter Original Comment Text Forest Service Response Number Also, because the implementation of the national Travel Management Although the comment is correct in indicating that alternative A as 2512 Rule is not an option but a requirement for the Tonto National Forest written would not comply with the Travel Management Rule, it is still Responsible Official, Alternative A, the no action alternative that would part of the NEPA analysis required for motor vehicle use designation continue to allow cross-country travel in most area, is not really a on the Tonto. As it is written, alternative A serves as the baseline, the viable alternative. It therefore does not warrant any further discussion current condition, for which the other alternatives can be compared to. from the County's perspective. The NEPA process allows for alternatives to be modified in the final decision. Alternative A could be modified to meet the Travel Management Rule, and is thus still up for consideration by the deciding official. Alternative Plan B would have the most benefit with regard to the Wildlife is one of many considerations that the Forest Supervisor, as 1281 Migratory Bird Treaty Act, and thus, wildlife in general. the deciding official for travel management, must take into consideration when determining the future of the motor vehicle use on the Tonto National Forest. As a supporter of quiet recreation and greater protections for our The final Travel Management Rule was designed to address the 33 precious wildlife, I think your proposed management plan can be commenter's suggestion by recognizing "The growing popularity and revised to better protect our public lands. Alternative B comes closest - capabilities of OHVs demand new regulations, so that the Forest - but does not go nearly far enough -- to providing a responsible Service can continue to provide these opportunities while sustaining management plan for off-road vehicles that recognizes and safeguards the health of National Forest System lands and resources" (Federal other uses and users of the national forest. Register, Volume 70, Number 216, page 68264–68265). By following the regulations and direction outlined in the rule, the Tonto will be taking all of the commenter's concerns into consideration. While Alternative B is the most protective alternative offered relative to Comment is an opinion and lacks "supporting reasons for the 1101 these areas and the Tonto's important resources, revisions are responsible official to consider" per 36 CFR 218.2. No further necessary in order to provide further protections. response warranted. I hope the final designation and decommissioning of motorized routes The final Travel Management Rule was designed to address the 2498 will reflect a better balance between motorized recreation and commenter's suggestion by recognizing "The growing popularity and protection for air, climate, soil, and stream resources than current capabilities of OHVs demand new regulations, so that the Forest conditions provide. Alternative B comes closest to this balance. Service can continue to provide these opportunities while sustaining the health of NFS lands and resources" (Federal Register, Volume 70, Number 216, page 68264–68265). By following the regulations and direction outlined in the rule, the Tonto will be taking all of the commenter's concerns into consideration.

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Comment Letter Original Comment Text Forest Service Response Number It eliminates roads in roadless areas and supports the conservation Route density is one of many metrics that can display the differences 2498 efforts of abutting communities with limited and compatible route between alternatives and is one of many considerations that the Forest interfaces. It does have deficiencies that could be addressed as Supervisor, as the deciding official for this project, took into follows: 1. Identify a system of designated motorized routes that (a) consideration when determining the future of the motor vehicle use on achieves a Forest- wide density of one road mile to one square mile of the Tonto National Forest. In chapter 3 of the final EIS, both the Forest (excluding roadless areas, wilderness areas, and Wild- “Wildlife Habitat Resources” and “Hydrology Resources” sections designated river corridors); and (b) can be monitored and maintained analyzes the effects of route density on the natural resources. As for a with a repair cycle not greater than 12 months, within existing budget, system that can be monitored and maintained, both the “Transportation staff, and equipment resources. 2. Make all designated motorized Facilities” and “Recreation” sections in chapter 3 analyze for this roads and trails subject to high wind and wet weather travel metric. In addition, existing and future partnerships with stakeholder restrictions. These provide for temporary closure when (a) air groups and other agencies can help with these needs. The Tonto turbulence suspends and moves soil particles causing haze or erosion; National Forest is subject to air quality standards as determined by the and (b) heavy rain or ice causes soil saturation or dangerous driving EPA and Maricopa County and will continue to comply with those conditions. 3. Issue federal use permits to allow Tribal members requirements. Special use permits for Tribes and other permitted users motorized access to undesignated routes to sacred sites and of National Forest System lands are outside the scope of this project traditional cultural properties. 4. Eliminate the Sycamore Permit Zone, and will be handled as necessary under additional environmental because it would be difficult to conduct effective enforcement. In analysis as appropriate. Sycamore Permit Zone is not designated per addition, include the eight areas identified as suitable for seasonal, the draft record of decision, which also designates spur motorized trails year-round, and youth cross-country OHV use. 5. Designate 300-foot- for full-sized four-by-four vehicles. wide corridors along all appropriate roads for dispersed motorized camping. Eliminate dispersed motorized camping within existing and potential Wild & Scenic River corridors, but permit it adjacent to the six Recreation-designated segments. We strongly support the adoption of Alternative B. We believe this is The final Travel Management Rule was designed to address the 29 the best approach of those offered to minimize further degradation commenter's suggestion by recognizing "The growing popularity and (and possibly even reclaim portions) of the Tonto National Forest capabilities of OHVs demand new regulations, so that the Forest (TNF). Service can continue to provide these opportunities while sustaining the health of National Forest System lands and resources" (Federal Register, Volume 70, Number 216, page 68264–68265). By following the regulations and direction outlined in the rule, the Tonto will be taking all of the commenter's concerns into consideration. We support the decision not to designate any additional routes or Comment is an opinion and lacks "supporting reasons for the 2472 motorized trails within IRAs. Further, we support Alternative B which responsible official to consider" per 36 CFR 218.2. No further will limit the number of route miles to 2.7. response warranted.

174 Volume II–Response to Comments

Comment Letter Original Comment Text Forest Service Response Number Alternative B should not be considered as it does not meet the Comment is an opinion and lacks "supporting reasons for the 5 requirement for recreational needs responsible official to consider" per 36 CFR 218.2. No further response warranted. Even in Alternative B, which appears to be the environmentally Comment is an opinion and lacks "supporting reasons for the 29 preferred alternative, there would still be 894 miles of roads plus 1,666 responsible official to consider" per 36 CFR 218.2. No further miles of motorized tracks, for over a total of 2,560 miles. This spider response warranted. web of roads and tracks, many of which were created by individuals and groups on their own without US Forest Service approval, creates a biological nightmare for plant and animal species, not to mention human species that might want to enjoy some quiet and pristine desert mountain scenery. Based on the merit of the action alternatives presented, and in further While the Tonto National Forest respects the county's desire to have 2512 consideration of the monumental change that the elimination of motor vehicle use on the Forest that meets the county's needs, there indiscriminate cross-country travel will represent for the culture and are other considerations that the deciding official, the Forest custom of the residents of and visitors to the County, Gila County Supervisor, must take into consideration as he designates motor wants to register its objection to the approximately 2,367 miles of vehicle use on the Tonto. roads decommissioning proposed in Alternative B. County wants to communicate unambiguously to the Tonto National While the Tonto National Forest respects the county's desire to have 2512 Forest its opposition to Alternative B. Gila County understands the motor vehicle use on the Forest that meets the county's needs, there NEPA requirement for the Tonto National Forest to analyze several are other considerations that the deciding official, the Forest significantly different alternatives, and Gila County acknowledges and Supervisor, must take into consideration as he designates motor appreciates the existence of constituencies favoring alternatives such vehicle use on the Tonto. as Alternative B. However, Gila County cannot support an alternative that would result, among others, in the closing of approximately 2,367 miles of roads, in the suppression of dispersed motorized camping, and in the suppression of motorized big game retrieval. This alternative is so departed from the Gila County residents' past, current, and foreseeable future custom, culture and economic well-being needs, and from the Gila County Motorized Travel and Recreation Management Objectives, that it does not warrant any further discussion from the County's perspective. I absolutely support changing the existing paradigm regarding cross- The final Travel Management Rule was designed to address the 30 country motorized vehicle travel. All forest service lands should be commenter's suggestion by recognizing "The growing popularity and closed to such motorized travel unless specifically open by road, trail capabilities of OHVs demand new regulations, so that the Forest or area. I also support the approach of inventorying existing roads; Service can continue to provide these opportunities while sustaining

175 Travel Management on the Tonto National Forest

Comment Letter Original Comment Text Forest Service Response Number both official and wild-cat, to determine which roads should be open in the health of National Forest System lands and resources" (Federal the future to serve the needs of recreational users while still protecting Register, Volume 70, Number 216, page 68264–68265). By following forest resources. In general, I believe your proposed Alternative C the regulations and direction outlined in the rule, the Tonto will be does a great job in achieving this balance. taking all of the commenter's concerns into consideration. I would like to express my option for option C to help conserve the Comment is an opinion and lacks "supporting reasons for the 1458 forest. responsible official to consider" per 36 CFR 218.2. No further response warranted. I find that Alternative C presents the most feasible, effective and The final Travel Management Rule was designed to address the 2404 balanced alternative to reduce and/or mitigate the increasing impacts commenter's suggestion by recognizing "The growing popularity and of Off Highway Vehicle use on forest lands including, but not limited to capabilities of OHVs demand new regulations, so that the Forest those supporting Sonoran Desert landscapes. Service can continue to provide these opportunities while sustaining the health of National Forest System lands and resources" (Federal Register, Volume 70, Number 216, page 68264–68265). By following the regulations and direction outlined in the rule, the Tonto will be taking all of the commenter's concerns into consideration. The road and motorized trail system presented in Alternative C, with a The Department is one of many agencies and authorized forest users 2497 few exceptions noted below, would allow the Department to use that will have the ability to be granted administrative use rights. It is hunters as a game management tool and meet game harvest the intent of the Tonto National Forest to work with other state and objectives. However, there are some roads and motorized trails in local agencies, along with authorized land users, to determine where Alternative C that are designated as "Administrative Use Only" that and how administrative use authorization will be granted. provide access to wildlife water developments that periodically need maintenance. To fulfill wildlife management responsibilities, the Department, including its authorized agents and volunteers, must be given authorization through this decision to access those waters for the purposes of maintenance and monitoring. We believe that Alt C including the changes proposed by AZOHVC The final Travel Management Rule was designed to address the 2506 and TRAL provides a basis for the development of a comprehensive commenter's suggestion by recognizing "The growing popularity and OHV travel plan which we see as a critical step towards having a well- capabilities of OHVs demand new regulations, so that the Forest managed, sustainable trail network that meets the public’s needs. This Service can continue to provide these opportunities while sustaining includes but is not limited to support facilities like staging areas, tot the health of National Forest System lands and resources" (Federal lots, trials areas and clear plans to restore (where required), Register, Volume 70, Number 216, page 68264–68265). By following adequately sign and maintain the trail network with volunteer support. the regulations and direction outlined in the rule, the Tonto will be taking all of the commenter's concerns into consideration.

176 Volume II–Response to Comments

Comment Letter Original Comment Text Forest Service Response Number One of our major concerns with the DEIS is the selection of Alternative Comment is an opinion and lacks "supporting reasons for the 2471 C as the preferred alternative. Alternative C does not adequately responsible official to consider" per 36 CFR 218.2. No further protect our public land resources. There is an inherent conflict response warranted. between user access and resource protection under current management that would not be resolved under Alternative C. Alternative C is also too heavily biased in favor of motorized use at the expense of forest/public resources. Under Alternative C, the Forest Service would designate a travel Comment is an opinion and lacks "supporting reasons for the 2471 management plan for the TNF that fails to protect forest resources for responsible official to consider" per 36 CFR 218.2. No further future generations and also fails to meet its legal obligations for response warranted. protection of various areas and resources under federal law. Gila County respectfully requests that Alternative C in the Draft While the Tonto National Forest respects the county's desire to have 2512 Environmental Impact Statement for the Tonto National Forest Travel motor vehicle use on the Forest that meets the county's needs, there Management Plan be rejected as relates to motorized travel and are other considerations that the deciding official, the Forest recreation. Specifically, under Alternative C: 1) Approximately 1,290 Supervisor, must take into consideration as he designates motor miles of roads are scheduled for decommissioning. 2) The travel vehicle use on the Tonto. management plan DEIS limits the species of big game allowed for motorized big game retrieval to elk and bear only. 3) The travel management plan DEIS limits motorized big game retrieval to a one mile corridor on both sides of designated roads and motorized trails, resulting in only 1,293,178 acres (45% of the Tonto National Forest total area) being reachable. 4) The travel management plan DEIS limits dispersed camping to a 100 feet corridor on both sides of designated roads and motorized trails. 5) The travel management plan DEIS limits personal use fuel wood gathering in permitted areas to a 300 feet corridor on both sides of designated roads and motorized trails. 6) The travel management plan DEIS does not address specifically dispersed shooting. My preference would be Alternative D, as my experience has been The final Travel Management Rule was designed to address the 5 that the dispersed use due to the greater amount of open roads results commenter's suggestion by recognizing "The growing popularity and in less impact, the greater amount of open and used routes helps capabilities of OHVs demand new regulations, so that the Forest prevent the spread of wildfires and provides better access to Service can continue to provide these opportunities while sustaining suppression of wildfires, and as currently written and mapped, analysis the health of National Forest System lands and resources" (Federal and comments are more meaningful as a result of the ability to Register, Volume 70, Number 216, page 68264–68265). By following determine the usage of each route (see comment 1 above). the regulations and direction outlined in the rule, the Tonto will be taking all of the commenter's concerns into consideration.

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Comment Letter Original Comment Text Forest Service Response Number I like Alternative D the most. It will help with the issues by decreasing The final Travel Management Rule was designed to address the 16 the amount of cross-country travel, yet leave a lot of roads open for commenter's suggestion by recognizing "The growing popularity and public use. It is a "baby-step" in the right direction. The issue can be capabilities of OHVs demand new regulations, so that the Forest re-visited after a few years. Service can continue to provide these opportunities while sustaining the health of National Forest System lands and resources" (Federal Register, Volume 70, Number 216, page 68264–68265). By following the regulations and direction outlined in the rule, the Tonto will be taking all of the commenter's concerns into consideration. I suggest your plan D as it seems to keep the most area open for the Comment lacks specific information and "supporting reasons for the 1100 largest communities. responsible official to consider" per 36 CFR 218.2. No further response warranted. Alternate D should be the preferred alternative, as it allows the public The final Travel Management Rule was designed to address the 2482 to access more than 12.3% of the surface area of the forest with their commenter's suggestion by recognizing "The growing popularity and vehicles, as compared to only 4% with Alternate C. The 300 foot capabilities of OHVs demand new regulations, so that the Forest dispersed camping limit is extremely important, although not needed Service can continue to provide these opportunities while sustaining very often, there are many beautiful traditional campsites that are the health of National Forest System lands and resources" (Federal beyond the 100 foot limit. This last weekend I camped in one of the Register, Volume 70, Number 216, page 68264–68265). By following prettiest campsites I have ever found, that had been used for years by the regulations and direction outlined in the rule, the Tonto will be others, that was more than 100 feet from the road, but less than 300 taking all of the commenter's concerns into consideration. feet. Safari Club International (SCI) submits these comments on the Draft The final Travel Management Rule was designed to address the 2502 Environmental Impact Statement for Travel Management for the Tonto commenter's suggestion by recognizing "The growing popularity and National Forest (Draft EIS). SCI supports Alternative D instead of the capabilities of OHVs demand new regulations, so that the Forest preferred alternative because Alternative D provides more extensive Service can continue to provide these opportunities while sustaining access and game retrieval opportunities for hunters. the health of National Forest System lands and resources" (Federal Register, Volume 70, Number 216, page 68264–68265). By following the regulations and direction outlined in the rule, the Tonto will be taking all of the commenter's concerns into consideration. As indicated in the Draft EIS, Alternative D resolves the following Part of this comment is an opinion and lacks "supporting reasons for 2502 problems that the proposed action would create: 1) the amount of the responsible official to consider" per 36 CFR 218.2. In addition, as roads and motorized trails provided by the proposed action does not was indicated in chapter 2 of the draft EIS and was reiterated in the meet the current and future needs for motorized recreation and access final EIS, the original proposed action was modified in response to throughout the Tonto National Forest; 2) the proposed action does not scoping comments. No alternative in the final EIS limits camping to 30 meet the needs for diverse motorized recreation activities; and 3) feet on each side of designated roads. limiting motorized access to dispersed camping to 30 feet from

178 Volume II–Response to Comments

Comment Letter Original Comment Text Forest Service Response Number designated roads may reduce dispersed camping opportunities, cause user conflict, and concentrate resource impacts. SCI supports Alternative D as preferable to Alternative C, the Service’s Comment is an opinion and lacks "supporting reasons for the 2502 preferred alternative. SCI finds it particularly significant that the responsible official to consider" per 36 CFR 218.2. No further planners added Alternative D in response to the public’s need for response warranted. increased recreation opportunities in the National Forest. Alternative D would help rectify these concerns. In addition, it would The ability to retrieve big game using a motor vehicle, along with the 2502 provide game retrieval opportunities for more of the species that species recognized as eligible for this type of retrieval, is one of many hunters seek in Tonto National Forest. In contrast to the proposed considerations that the Forest Supervisor, as the deciding official for alternative that would allow motorized access for game retrieval of elk travel management, must take into consideration when determining the and bear only, Alternative D also would allow access for mule deer future of the motor vehicle use on the Tonto National Forest. and white tail deer retrieval. Instead of the 1,293,178 acres that Alternative C would provide for motorized retrieval, Alternative D would provide access to 2,068,208 acres. Compared with current use, Alternative C proposes a greater overall reduction of total area allowed for game retrieval than Alternative D. Reducing or limiting retrieval access in any way will negatively impact SCI members and other hunters that already use motorized vehicles in the forest for game retrieval. The Service should choose the alternative that will allow the most access consistent with other necessary objectives. Although we prefer Alternative D to the proposed alternative, SCI does Nothing in the Tonto National Forest's decision to designate a motor 2502 not wish to suggest that forest planners should limit the opportunities vehicle use system will directly affect hunting within the Forest. Instead to hunters to those described in Alternative D, if additional designation could affect how a hunter accesses areas to scout and opportunities for access, game retrieval and camping opportunities can hunt, locations hunters might camp, and the distance and the type of be made available. SCI encourages the Forest Service to provide the species they can legally retrieve using a motor vehicle. most expansive opportunities possible to the hunting community, as long as those opportunities do not jeopardize the wildlife resources that SCI members hope to enjoy long into the future. Gila County therefore respectfully requests that the Selected While the Tonto National Forest respects the county's desire to have 2512 Alternative for the Final Environmental Impact Statement for the Tonto motor vehicle use on the Forest that meets the county's needs, there National Forest Travel Management Plan be based on Alternative D, are other considerations that the deciding official, the Forest and include the following modifications: 1) Not more than Supervisor, must take into consideration as he designates motor approximately 194 miles of roads scheduled for decommissioning. 2) vehicle use on the Tonto. As indicated in the draft record of decision, Motorized big game retrieval allowed for all species of game meeting nearly 1,300 miles of routes will be designated for decommissioning, the definition of 'big game' in the Arizona Game and Fish Department many of which may already be on the ground due to vegetation hunting regulations, or alternatively for all 'big game' animals requiring overgrowth. Motorized access for big game retrieval will be limited to

179 Travel Management on the Tonto National Forest

Comment Letter Original Comment Text Forest Service Response Number a hunting tag, with the exception of turkeys. 3) Motorized big game legally harvested elk and bear within one mile of both sides of retrieval allowed to consist of one trip each way from the downed designated routes, to minimize the effects to natural resources and animal to the closest legally open road or trail, regardless of distance, decrease potential conflicts between users in compliance with the final by the most direct route compatible with safety and the preservation of Travel Management Rule. In chapter 2 of the final EIS, under other values such as riparian areas, archeological sites,etc. 4) alternative C, an inventory of existing dispersed sites that were Dispersed motorized camping allowed in a 300 feet corridor on both accessible by a motor vehicle was conducted for the Tonto National sides of designated roads and motorized trails, AND in dispersed Forest. Instead of corridors, the Forest Supervisor decided to camping sites previously used and established in the local custom and designates short spur motorized trails to sites, excluding some in order culture as demonstrated by tangibles evidences of previous use such to continue to minimize effects of motor vehicle use. In terms of as fire pits, improvements, etc. 5) Personal use fuel wood gathering in motorized access for the purpose of personal use fuelwood gathering, permitted areas allowed to consist of the minimum number of trips the draft record of decision permits those that have a permit to travel each way, based on the transport capacity of the vehicle and the off of designated routes within designated fuelwood gathering areas. trailer, from the downed tree to the closest legally open road or trail, Recreational shooting and all activities related is outside the scope if regardless of distance, in the authorized firewood collection area, by this analysis. the most direct route compatible with safety and the preservation of other values such as riparian areas, archeological sites, etc. 6) A new category of motorized dispersed recreational shooting authorized to consists of one trip each way from the natural or artificial obvious terrain feature used as a backstop, such as pit, berth or features similar in their functionality as relates to safe dispersed shooting, to the closest legally open road or trail, regardless of distance but not more than one mile, by the most direct route compatible with safety and the preservation of other values such as riparian areas, archeological sites, etc. The AES would recommend the final decision to include a blend of The final Travel Management Rule was designed to address the 2405 Alternative C and D, especially as it relates to keeping roads as commenter's suggestion by recognizing "The growing popularity and motorized trails instead of administratively closing them. capabilities of OHVs demand new regulations, so that the Forest Service can continue to provide these opportunities while sustaining the health of National Forest System lands and resources" (Federal Register, Volume 70, Number 216, page 68264–68265). By following the regulations and direction outlined in the rule, the Tonto will be taking all of the commenter's concerns into consideration. I am sorry to have to choose NO CHANGE for the Tonto NF TM DEIS. Comment is an opinion and lacks "supporting reasons for the 1713 responsible official to consider" per 36 CFR 218.2. No further response warranted.

180 Volume II–Response to Comments

Comment Letter Original Comment Text Forest Service Response Number If we have to choose an alternative it would be A. If that is not possible Comment is an opinion and lacks "supporting reasons for the 2517 because of "Travel Management Rule" then our choice would be responsible official to consider" per 36 CFR 218.2. No further Alternative D but with NO ROAD CLOSURES. response warranted. As a property owner with land bordering the TNF, I favor Pan B as Comment lacks "supporting reasons for the responsible official to 1281 currently presented. This alternative addresses most of my concerns. consider" per 36 CFR 218.2. No further response warranted. My choice is PLAN B. It is clear that humans can't manage these Comment is an opinion and lacks "supporting reasons for the 1491 areas without some control by our assigned managers. responsible official to consider" per 36 CFR 218.2. No further response warranted. I would be in favor of alternative C. Comment lacks "supporting reasons for the responsible official to 10 consider" per 36 CFR 218.2. No further response warranted. If there are ongoing problems, then Alternative C could be adopted. Comment lacks "supporting reasons for the responsible official to 16 consider" per 36 CFR 218.2. No further response warranted. Alternative C would allow motorized access to 1.3 million acres of the Comment is an opinion and lacks "supporting reasons for the 29 TNF. This is over 40% of the TNF. Alternative D would allow motorized responsible official to consider" per 36 CFR 218.2. No further access to over two-thirds of the TNF. Apparently, the National Forest response warranted. Service should consider changing its name to the Motorized Vehicle Service. Consider this e-mail as additional input to be placed in RRO's file at Comment lacks "supporting reasons for the responsible official to 1234 TNF supporting TMP ALT. "C" Plan. consider" per 36 CFR 218.2. No further response warranted. I am in strong support of option C. Comment lacks "supporting reasons for the responsible official to 1272 consider" per 36 CFR 218.2. No further response warranted. Please consider option C. Comment lacks "supporting reasons for the responsible official to 1272 consider" per 36 CFR 218.2. No further response warranted. I favor Alternative C except for two proposed road closing. Comment lacks "supporting reasons for the responsible official to 1441 consider" per 36 CFR 218.2. No further response warranted. I support Option C of the Tonto National Forrest. Comment lacks "supporting reasons for the responsible official to 1469 consider" per 36 CFR 218.2. No further response warranted. I support Plan 'C' at this time. We must strive to strike a balence Comment is an opinion and lacks "supporting reasons for the 1719 between Loving the wild places and Loving them to death. responsible official to consider" per 36 CFR 218.2. No further response warranted.

181 Travel Management on the Tonto National Forest

Comment Letter Original Comment Text Forest Service Response Number I agree with my fellow SALT member when he says - we have to strike Comment is an opinion and lacks "supporting reasons for the 1825 a balance between Loving the Wilderness and Loving it to Death. I feel responsible official to consider" per 36 CFR 218.2. No further option C is the right balance of access and preservation. response warranted. I am in strong support of option C. Comment lacks "supporting reasons for the responsible official to 2085 consider" per 36 CFR 218.2. No further response warranted. I write in support of Option C. Comment lacks "supporting reasons for the responsible official to 2407 consider" per 36 CFR 218.2. No further response warranted. I support using Alt. C. Comment lacks "supporting reasons for the responsible official to 2481 consider" per 36 CFR 218.2. No further response warranted. Alternative D is the best solution. Comment lacks "supporting reasons for the responsible official to 3 consider" per 36 CFR 218.2. No further response warranted. I propose either Plan D(my first choice) or Plan C. Comment lacks "supporting reasons for the responsible official to 20 consider" per 36 CFR 218.2. No further response warranted. I wish to express my support for Alternative D (1st choice) or C. Comment lacks "supporting reasons for the responsible official to 22 consider" per 36 CFR 218.2. No further response warranted. My first preference is alternative D, with C as my second choice. Comment lacks "supporting reasons for the responsible official to 28 consider" per 36 CFR 218.2. No further response warranted. Of the four options presented in your report, option Dis the most Comment lacks "supporting reasons for the responsible official to 1716 desirable. consider" per 36 CFR 218.2. No further response warranted. Therefore, given the choices presented in the DEIS, Alternative D the Comment lacks "supporting reasons for the responsible official to 2495 preferable solution. consider" per 36 CFR 218.2. No further response warranted. As the proposal stands, we are opposed to it. Comment lacks "supporting reasons for the responsible official to 18 consider" per 36 CFR 218.2. No further response warranted. The option with motorized all around all the water sources is just crazy Comment is an opinion and lacks "supporting reasons for the 1272 - who can think that is a good option. The wildlife I am sure do not !! as responsible official to consider" per 36 CFR 218.2. No further well as the majority of outdoor enthusiasts. response warranted. The option with motorized all around all the water sources is just crazy Comment is an opinion and lacks "supporting reasons for the 2085 - who can think that is a good option. The wildlife I am sure do not !! as responsible official to consider" per 36 CFR 218.2. No further well as the majority of outdoor enthusiasts. Unfortunately, at too many response warranted. meeting over the last 20 yrs it is the motorized folks that can activate their members in droves. I am afraid that will skew your input.

182 Volume II–Response to Comments

Comment Letter Original Comment Text Forest Service Response Number After some discussion, the Council made a motion to give their support While the Tonto National Forest respects the county's desire to provide 2522 to Alternative D. I am writing this letter on behalf of the Town council of input, the comment lacks "supporting reasons for the responsible the Town of Superior, to state their preference is Alternative D. The official to consider" per 36 CFR 218.2. No further response warranted. council appreciates your efforts on this project, and thanks for the . consideration of Alternative D as the accepted choice to implement the Travel Management Plan. Unless specifically noted, all remaining comments are based on the In the commenter's letter, they outline specific recommendations which 5 map and route designations for Alternative D, but will apply to all are addressed in the Route Specific section of this table. alternative assuming that the routes described in the comments below are open to full size vehicles. Baseline Determination: The appropriate baseline of existing open Nowhere in the final Travel Management Rule is there a requirement to 2471 system routes consists of those routes which have been documented complete what the commenter is requesting. In 36 CFR 212.50(b), in relevant NEPA analysis. Any routes lacking documentation should “The responsible official may incorporate previous administrative be analyzed as new unauthorized routes, in recognition that there is no decisions regarding travel management made under other authorities, record of administrative decision or analysis addressing the including designations and prohibitions of motor vehicle use, in environmental impacts of motor vehicle use on these routes, and that designating National Forest System roads, National Forest System the Forest Service is unsure as to origin of some routes. Although we trails, and areas on National Forest System lands for motor vehicle use recognize the challenges associated with locating adequate supportive under this subpart." As articulated in detail in chapter 2 of the final EIS, documentation given a past history of poor recordkeeping, we in the section titled “Alternatives Considered but Eliminated from fundamentally reject the position that the baseline should be based Detailed Study,” we believe that nearly all of the 5,000 miles of routes entirely on a best guess by the Forest Service, rejecting prior NEPA in the baseline, no-action alternative (alternative A) have had a NEPA analysis. analysis, either through the 1985 Forest Plan Record of Decision or through the RATM decision. To address this issue, we strongly recommend that the Forest Service The suggested “route evaluation spreadsheet” submitted by the 2471 develop a documentation spreadsheet which would supplement the commenter (appendix B to their comment letter) has no relationship to description of the no-action alternative, and would eventually the final Travel Management Rule and the requirements for accompany the MVUM. This spreadsheet would summarize the NEPA designation of a motor vehicle use system on the Tonto National decisions, together with other relevant documentation (e.g., formal Forest. As part of the analysis process to comply with the rule (detailed adoption of road/trail objectives for the route; information establishing in chapter 2 of the final EIS, in the section titled “Alternatives consistent maintenance expenditures over time, etc.) supporting the Considered but Eliminated from Detailed Study”) we believe that nearly inclusion of each route on the authorized system. We have included a all of the 5,000 miles of routes in the baseline, no-action alternative sample spreadsheet to serve as an example. See Appendix B. Such (alternative A) have had a NEPA analysis, either through the 1985 documentation would include NEPA analysis and decision documents Forest Plan Record of Decision or through the RATM decision. In and reasons why the route satisfies route designation criteria (see addition, as outlined in appendix A of the Transportation report, an section 3 of Executive Order 11644; 36 C.F.R. § 212.55). Routes initial examination of the road system found in Infra was conducted lacking such documentation should be marked accordingly, and if the from the perspective of engineering needs. Once this was done,

183 Travel Management on the Tonto National Forest

Comment Letter Original Comment Text Forest Service Response Number Forest Service proposes to designate the route in the action resource specialists, along with Forest Service law enforcement alternatives, it must include site-specific analysis of that route in this personal and Arizona Game and Fish Department wildlife managers process. reviewed the system to determine what would be the modified proposed action based on on-the-ground knowledge of the route and current resource conditions. Detailed accounts of this process can be found in the project record in the Supervisor's Office in Phoenix, Arizona. After the draft EIS comment period, routes were again analyzed at the district level, with input from district biologists, silviculturists, para-archeologists, and range and recreation staff, along with Forest Service law enforcement officers, Arizona Game and Fish Department game enforcement officers, and district rangers, many of whom had participate in trips to the field to assess current conditions on the ground. These routes were reviewed based on use—either for public or permitted use access with an emphasis on assessing potential user conflicts—and resource protection—including effects to watersheds, vegetation, wildlife habitat, and water resources as required in the final Travel Management Rule (36 CFR 212.55). These meetings were conducted in late January and early February of 2015, and involved site-specific knowledge and the use of the most recent areal imagery. The TNF should describe the baseline system as outlined above, Comment is an opinion and lacks "supporting reasons for the 2471 limiting routes described as open to public use to those that are responsible official to consider" per 36 CFR 218.2 outside of the above actually officially open to public use (ML 2-5), as shown in Table 2. It submitted comments which have been specifically responded to. No should then discuss the alternatives appropriately, so that the real further response warranted. impact of the alternatives and the proposed changes from the baseline open route system is clear and fully disclosed to the public. Failure to do so creates a fatal flaw in the EIS and any decision that is based upon that lack of disclosure and analysis. TNF should describe the baseline system as we recommend above. In implementing this decision, no routes that have been physically 2471 For those roads or trails that meet the aforementioned criteria closed (ML 1) or physically decommissioned as a result of past undertake the necessary historic properties survey requirements and analysis and decisions are designated to be reopened or consultation with Arizona State Historic Preservation Office as outlined reconstructed, either as a motorized trail or road. As outlined in the in the Protocol. Based on the INFRA database, Alternative C proposes affected environment section of the Heritage Resources report, “the an additional 2000 miles of roads that would need to be assessed for Forest currently contains 4,959 miles of roads open to the public, many historic resources based on the Protocol requirements before these of which, owing to high archaeological and historical site density, have routes could be designated or appear on an MVUM. inevitably impacted a variety of cultural resources. Many of these roads

184 Volume II–Response to Comments

Comment Letter Original Comment Text Forest Service Response Number originated in the late 19th century and have been in continual use ever since. Many more were built prior to the passage of the 1966 National Historic Preservation Act, and were constructed without regard for their potential impacts to archaeological or historic sites. As a result, hundreds of archaeological sites on the Tonto National Forest have been documented in the inventory as having been damaged by past road construction and maintenance activities. The Southwestern Region Programmatic Agreement between the Advisory Council on Historic Preservation, Forest Service Region 3 and the State Historic Preservation Officers (SHPOs) of New Mexico, Texas, Oklahoma and Arizona (1994, as amended 2003, hereafter referred to as the Programmatic Agreement) recognizes this situation and accepts that continued use and routine maintenance of system roads and motorized trails, even where there are known historic properties or cultural resources, does not necessarily constitute an adverse effect to these properties when the proposed work is clearly confined to previously disturbed contexts and will not increase or expand this disturbance … Both the National Policy and the Region 3 protocol hold that a decision to designate a system of already existing roads and trails currently open for motor vehicle use will have little or no potential to affect historic properties.” Chapter 2 of the final EIS, “Alternatives Considered but Eliminated from Detailed Study,” attempts to reconcile the direction from the Regional Programmatic Agreement, past analysis of roads that was conducted for the 1985 Forest Plan and the 1990 RATM decision, and what currently exists on the ground. This was done by conducting an initial examination of the road system found in Infra from the perspective of engineering needs. Once this was done, resource specialists, along with Forest Service law enforcement personal and Arizona Game and Fish Department wildlife managers reviewed the system to determine what would be the modified proposed action based on on-the-ground knowledge of the route and current resource conditions. Detailed accounts of this process can be found in the project record in the Supervisor's Office in Phoenix, Arizona. After the draft EIS comment period, routes were again analyzed at the district level, with input from district biologists, silviculturists, para- archeologists, and range and recreation staff, along with Forest Service law enforcement officers, Arizona Game and Fish Department

185 Travel Management on the Tonto National Forest

Comment Letter Original Comment Text Forest Service Response Number game enforcement officers, and district rangers, many of whom had participate in trips to the field to assess current conditions on the ground. These routes were reviewed based on use—either for public or permitted use access with an emphasis on assessing potential user conflicts—and resource protection—including effects to watersheds, vegetation, wildlife habitat, and water resources as required in the final Travel Management Rule (36 CFR 212.55). These meetings were conducted in late January and early February of 2015, and involved site specific knowledge and the use of the most recent areal imagery. As a responsible user of motorized recreational routes I am in favor of As indicated in the draft record of decision, there will be approximately 13 Alternative D, but am also open to Alternative C. For me the most 110 miles of motorized trails designated for single-track use. Under the important thing is to have motorized singletrack for motorcycle use, “Public Comments on the Proposed Rule and Department Responses” and the more the better. section of the 2005 Travel Management Rule (Federal Register, Volume 70, Number 216, page 68283) states "Since the system of designated routes and areas will change over time, the Department anticipates that local units will publish new motor vehicle use maps annually and update signs as necessary or appropriate.” The designated roads, motorized trails, and areas will be reviewed annually. We support the following components of Alternative B: only .05 miles Comment is an opinion and lacks "supporting reasons for the 2472 of motorized routes for administrative use only in the Proposed Picket responsible official to consider" per 36 CFR 218.2. In the draft record Post Mountain RNA; no motorized routes within the Proposed Upper of decision, the proposed Picket Post Mountain and Upper Forks Forks Parker Creek RNA. Parker Creek research natural areas, the motorized routes (0.05 miles and 0.55 respectively) are designated administrative use only and not open to public motor vehicle use.

186 Volume II–Response to Comments

General Comments and Responses Comment Letter Original Comment Text Forest Service Response Number I am very pleased to see this project being carried out. I live on both the Comment lacks "supporting reasons for the responsible official to 1491 north and the south end of the Tonto forest and am very concerned consider" per 36 CFR 218.2. No further response warranted. about its management. I am writing to submit comments in regards to your revision of the Tonto Completing the designation of motor vehicle use on the Tonto 1711 National Forest Land and Resource Management Plan (LRMP). National Forest will update the existing condition for the motorized system for the upcoming revision of the Tonto National Forest Plan. Comments specifically related to Forest Plan revision are outside the scope of this analysis, which complies with the final Travel Management Rule. Please take a hard look at the proposed plan and choose a final The final Travel Management Rule was designed to address the 1101 alternative that incorporates the most protective measures for the commenter's suggestion by recognizing "The growing popularity and lands, the wildlife, and the people who enjoy them. capabilities of OHVs demand new regulations, so that the Forest Service can continue to provide these opportunities while sustaining the health of National Forest System lands and resources" (Federal Register, Volume 70, Number 216, page 68264–68265). By following the regulations and direction outlined in the rule, the Tonto will be taking all of the commenter's concerns into consideration. We believe the Travel Management Plan is necessary to prevent further The final Travel Management Rule was designed to address the 2500 damage and unhealthy conditions for the Tonto Forest. At the same commenter's suggestion by recognizing "The growing popularity and time we wish to have the residents of Payson and surrounding capabilities of OHVs demand new regulations, so that the Forest communities protected for the safety, values of our homes and preserve Service can continue to provide these opportunities while sustaining the quality of life we as residents have chosen need to respected and the health of National Forest System lands and resources" (Federal considered in the overall management of travel within the Payson and Register, Volume 70, Number 216, page 68264–68265). By following Tonto Travel Management Plan. the regulations and direction outlined in the rule, the Tonto will be taking all of the commenter's concerns into consideration. As for the rest of the Travel Management Plan it is difficult to know what The final Travel Management Rule was designed to address the 2511 to say, I would hope the experts in this field will make the best decision. commenter's suggestion by recognizing "The growing popularity and We need to protect wildlife & its habitat, watersheds, environment, capabilities of OHVs demand new regulations, so that the Forest beauty, cultural & historic areas. To reduce & eliminate the off trail/road Service can continue to provide these opportunities while sustaining riding. the health of National Forest System lands and resources" (Federal Register, Volume 70, Number 216, page 68264–68265). By following the regulations and direction outlined in the rule, the Tonto will be taking all of the commenter's concerns into consideration.

187 Travel Management on the Tonto National Forest

Comment Letter Original Comment Text Forest Service Response Number We ask that the Tonto National Forest limit motorized travel to The final Travel Management Rule allows for the designation of OHV 2521 designated routes for all public land users - no exceptions needed. areas where motor vehicle use is permitted off of designated routes. This can include for accessing dispersed camping and the retrieval of big game. Alternative B was developed to substantially decrease the designation of OHV areas, limited to the retrieval of personal fuelwood. However, as indicated in the draft record of decision, motor vehicle use off of designated routes will be permitted for the retrieval of legally harvested elk and bear, for accessing fuelwood, and in designated OHV areas. I strongly believe that we will have a better tomorrow through education Comment is an opinion and lacks "supporting reasons for the 1100 and accountability than through heavy restriction and regulation but responsible official to consider" per 36 CFR 218.2. No further recognize that there is a place for both response warranted. see Canyon TMR comments,docx Duplication. The information in this attachment is also contained in 11 the original email, whose comments have been handled in this table. Tonto TMP Alt C Map.docx Duplication. The information in this attachment is also contained in 11 the original email, whose comments have been handled in this table. Attachment: ZimmermanWell.pdf Duplication. The information in this attachment is also contained in 21 the original email, whose comments have been handled in this table. Attachment: Ltr 2500 DC-260-B2347C226 Duplication. The information in this attachment is also contained in 2500 the original email, whose comments have been handled in this table. I am attaching a few staging areas that should be considered when The designation of staging areas are outside the scope of the 2500 planning for travel in the Payson Ranger District to benefit the OHV decisions being considered for this project. This information will be experience. passed on to the specific ranger district for further consideration. Please note that there are supplemental map documents supporting The route specific information was received and responses related to 2510 these comments which were hand delivered to the Tonto National suggested route changes or additions is addressed in the Route Forest Supervisor's Office on a CD on September 17, 2014 Specific section of this table. Please see cd attachment for specific route changes The route specific information was received and responses related to 2510 suggested route changes or additions is addressed in the Route Specific section of this table. AZOHVC 2014 TNF EIS comments Duplication. The information in this attachment is also contained in 2518 the original email, whose comments have been handled in this table. co of all data and maps in PDF format Duplication. The information in this attachment is also contained in 2518 the original email, whose comments have been handled in this table.

188 Volume II–Response to Comments

Comment Letter Original Comment Text Forest Service Response Number Detail Area files: -CCRD Parking staging areas -FR 160 CCRD Duplication. The information in this attachment is also contained in 2518 crossing data -AZOHVC/TNF CCRD state parks trail maintenance the original email, whose comments have been handled in this table. grant work -2013 horse trail impacts on TNF CCRD Detail maps: -2014 Wildcat Staging area (Desert Vista) single track Duplication. The information in this attachment is also contained in 2518 Map# 5 PDF -St Claire Peak area, North Permit zone Map #6 PDF - the original email, whose comments have been handled in this table. I44th street/1109 area Horse trails Map #7 PDF -GPS track ofDV and StClaire North area Map #8 PDF Please find enclosed our comments on the 2014 TNF EIS. Duplication. The information in this attachment is also contained in 2518 the original email, whose comments have been handled in this table. We have four main maps based on your map C: Map 1/ Coverall Duplication. The information in this attachment is also contained in 2518 AZOHVC comments Map 2/ C cropped insert 4 routes AZOHVC the original email, whose comments have been handled in this table. comments Map 3/ C cropped insert 4 single track routes/connectors AZOHVC comments Map 4/ C cropped insert 4 single track routes AZOHVC comments RRO representing 200 + members still support all the Duplication. The information in this attachment is also contained in 1234 recommendations, comments and suggestions provided to TNF since the original email, whose comments have been handled in this table. the onset of the TMP planning activity. The Board has and continues to support closing the forest to off-road Comment is an opinion and lacks "supporting reasons for the 1712 cross country motorized travel as well as closing redundant motorized responsible official to consider" per 36 CFR 218.2. No further routes. We believe this shift from current management will benefit the response warranted. conservation of our forest lands well into the future. Language should be added that addresses the need to eliminate cross- The purpose of and need for this project includes "The purpose of this 2471 country travel, the current and past resource damage that has occurred project is to comply with the Travel Management Rule by providing a due to unregulated OHV use, the lack of adequate enforcement, and system of roads, trails, and areas designated for motor vehicle use by continuing user conflicts between motorized and non-motorized users. class of vehicle and time of year on the Tonto National Forest" Disclosing these realities will help to better align the outcome of this (chapter 1 of the final EIS), which satisfies the commenter’s request in process with the actual needs and purpose of this action and the its entirety. The final Travel Management Rule requires “…the requirements and intent of federal law. responsible official shall consider effects on the following, with the objective of minimizing: (1) Damage to soil, watershed, vegetation, and other forest resources; (2) Harassment of wildlife and significant disruption of wildlife habitats; (3) Conflicts between motor vehicle use and existing or proposed recreational uses of National Forest System lands or neighboring Federal lands; and (4) Conflicts among different

189 Travel Management on the Tonto National Forest

Comment Letter Original Comment Text Forest Service Response Number classes of motor vehicle uses of National Forest System lands or neighboring Federal lands” (36 CFR 212.55(b)). Implement sensible restrictions on indiscriminate cross-country travel in The final Travel Management Rule was designed to address the 2512 order to preserve and conserve the resources contained in the Tonto commenter's suggestion by recognizing "The growing popularity and National Forest for the enjoyment of future generations. Indiscriminate capabilities of OHVs demand new regulations, so that the Forest cross-country travel consists of traveling cross-country in a motorized Service can continue to provide these opportunities while sustaining vehicle not intended to reach a specific dispersed camp site, downed the health of National Forest System lands and resources" (Federal animal, downed tree in an authorized firewood collection area, or terrain Register, Volume 70, Number 216, page 68264–68265). As indicated feature used as a shooting backstop, or not required for an emergency in the draft record of decision, many of the commenter's concerns are response to a specific justifiable circumstance such as danger to limb or addressed with the designated motorized system for the Tonto life. Motorized scouting for a site is considered different from reaching a National Forest. specific site and is not authorized. Please review this document of yours listed online: (http://a123.g.akam An attempt to access this website as submitted by the commenter 1716 ai.net/7 /123/11558/a bc123/forestservic. download.a kamai.com/11 was made on January 2, 2015. The webpage could not be found as 558/www/nepa/59232_FSPLT2_05101S.pdf) submitted by commenter. Reference documents for AZOHVC 2014 EIS comments: -2012_ Duplication. The information in this attachment is also contained in 2518 AZOHVC 4 E's PDF -Trail maintenance as dust mitigation and BMP the original email, whose comments have been handled in this table. data -2012_ AZOHVC 10.24.11 AQ BMP PM 10 dust mitigation.pdf(excepted by Co, State and EPA for mitigation ofPMlO issues on recreational trail systems) -2012_11.16.11AQ _BMP (AZ DEQ Director correspondence on BMP and dust rules as applying to OHV)) -2012_10.24.1 IAQ Eric Massey on BMP.pdf...... -2014 BLM AZOHVC 013114 4a restoration project -2014 BLM AZOHVC 050614 4a restoration project -2014 060114 2a Ranger AZOHVC work BLM - 2012_BLM AZOHVC_Ol0912 Ia Boulders MM14 rehab (Restoration work example BLM) -2014 BLM table mesa recreation area map Reference maps and documents from previous planning: -6.1.1 0 final Duplication. The information in this attachment is also contained in 2518 Needle Rock comments AZOHVC/ATR file -12.4.09 TNF TMR prelim the original email, whose comments have been handled in this table. comments package AZOHVC file -2012 submitted TMR documents AZOHVC file -2013 submitted documents TNF.TMR file -4.21.13 South option ofFR 1069 PDF -2014_ Appendix B Alt 2 AZOHVC Houston mesa PDF -ATR letter TNF 2013 EIS comments PDF -FR 42 4.24.13 options Desert Vista Trail System 2002 ATR_ TNF planning (CCRD actual Duplication. The information in this attachment is also contained in 2518 route system plan) the original email, whose comments have been handled in this table.

190 Volume II–Response to Comments

Comment Letter Original Comment Text Forest Service Response Number Our rivers and forests are part of our national heritage and the areas Comment is an opinion and lacks "supporting reasons for the 28 should be kept accessible as much as practicable for use by all responsible official to consider" per 36 CFR 218.2. No further response warranted. I hoped some reasonable alternative would work. But I am concerned Comment is an opinion and lacks "supporting reasons for the 1713 that the citizens are being denied access to their national lands. responsible official to consider" per 36 CFR 218.2. No further response warranted. How is closing a large number of roads to the public going to The intent of the final Travel Management Rule, along with Executive 2482 accommodate the current usage of the TNF and prepare for the future Orders 11644 and 11989, is to provide for motorized access while increases? minimizing the impacts to natural resources: "The growing popularity and capabilities of OHVs demand new regulations, so that the Forest Service can continue to provide these opportunities while sustaining the health of National Forest System lands and resources" (Federal Register, Volume 70, Number 216, page 68264–68265). Closing a road for safety is not a reason with a rational limit. Who are Comment is an opinion and lacks "supporting reasons for the 2482 you making the forest safe for and what chance of an accident are you responsible official to consider" per 36 CFR 218.2. No further managing for? response warranted. I have been enjoying the TNF for many years, and as I traveled thru the Comment lacks "supporting reasons for the responsible official to 2482 forest, I have always made mental notes of areas I would like to consider" per 36 CFR 218.2. No further response warranted. explore. I am aghast to see that you intend to close many of the roads I intended to explore. We are against any more road closures, any areas in the "statement" Comment is an opinion and lacks "supporting reasons for the 2517 that mention closing roads we are against. Why not consider opening responsible official to consider" per 36 CFR 218.2. No further some of the roads for vehicular use? Make some loop type trails with response warranted. varying degrees of difficulty, easy to very difficult. We could use our vehicles to actually four-wheel instead of just driving down a graded road. [Here are] my concerns about all these roads through the forest. It is Comment is an opinion and lacks "supporting reasons for the 26 quite clear to anybody with a brain that those roads mean wildlife and responsible official to consider" per 36 CFR 218.2. No further bird deaths. I totally oppose all these roads. They are not necessary. response warranted. They should be banned. I am glad to see the National forrest working to close some of the roads Comment is an opinion and lacks "supporting reasons for the 1719 in that impact in a negative fashion the ecology of the region responsible official to consider" per 36 CFR 218.2. No further response warranted.

191 Travel Management on the Tonto National Forest

Comment Letter Original Comment Text Forest Service Response Number I can see no justification for closing (or downgrading) all of these routes Comment lacks "supporting reasons for the responsible official to 554 consider" per 36 CFR 218.2. No further response warranted. A general comment about all roads that are selected for closure is that R.S. 2477 was adopted by Congress in 1866 and granted a right-of- 2 the RS2477 law should be considered. Many of these old ranching and way for the construction of highways across public land not reserved mining roads were in use and grandfathered into the law when RS 2477 for public uses. In the Federal Land Policy and Management Act was repealed in 1976. (FLPMA), enacted in 1976, Congress repealed R.S. 2477, but did not terminate valid rights-of-way existing on the date of FLPMA's enactment. It is up to a state agency to file for R.S. 2477 rights on roads that are within the jurisdiction of the Federal government (Ventures, Inc. v. Arizona; Fisher v. Golden Valley Elec. Ass'n., Inc. 658 P.2d, Alaska;1983 - citing United States v. Oklahoma Gas & Elec. Co. 328 U.S.; 1943.) There is no credibility to closing a road to recreationists, because of Comment is an opinion and lacks "supporting reasons for the 2482 alleged environmental damage, if you are planning to log or thin the responsible official to consider" per 36 CFR 218.2. No further area in the future. response warranted. There is no credibility to claim a road is being closed to protect a Comment is an opinion and lacks "supporting reasons for the 2482 riparian area, if you let cattle graze in the area. responsible official to consider" per 36 CFR 218.2. No further response warranted. I am curious if anyone from the Tonto main office has actually Comment is an opinion and lacks "supporting reasons for the 554 inventoried (visited) all of these roads? responsible official to consider" per 36 CFR 218.2. No further response warranted. A new road (trail) class was introduced for Alternatives C and D but High clearance roads are those that fall under the maintenance level 2405 they are not really defined. For example what is the difference between" 2 category, which is defined in the final EIS in the glossary of terms as high clearance" roads and "motorized trails''? Under the "Glossary of "Roads are maintained open for limited passage of traffic. Roads in Terms'' appendix motorized trails are defined but high clearance roads this maintenance level are primitive type facilities intended for high are not mentioned. It is our understanding that motorized trails are only clearance vehicles. Passenger car traffic is not a consideration." How part of the trails network but since they are being used by motorized a motorized trail and ML 2 road are different is detailed in the vehicles it would be good at least to reference them in the description of alternative C in chapter 2 of the final EIS. The greatest transportation section. difference is type and frequency of maintenance required for each type. The Department recognizes and supports the need to better manage In chapter 2 of the final EIS, under alternative C, an inventory of 2497 dispersed camping to manage natural resource damage. However, the existing dispersed sites that were accessible by a motor vehicle was Department anticipates camping restrictions will lead to a shortage of conducted for the Tonto National Forest. Instead of corridors, the available camp sites affecting the ability and/or willingness of all lawful Forest Supervisor decided to designates short spur motorized trails to forest users to hunt and fish and enjoy the splendor of forest lands.

192 Volume II–Response to Comments

Comment Letter Original Comment Text Forest Service Response Number Therefore the Department requests the Forest incorporate the 300 ft. sites, excluding some in order to continue to minimize effects of motor standard (dispersed camping allowed up to 300ft from designated vehicle use, as indicated in the draft record of decision. routes) consistent with other forests in Arizona. In addition, the Department has been collaboratively working with the Tonto National Forest to provide an inventory of motorized dispersed camping sites across the Forest. These data must be used to inform your decision as it will capture existing and frequently used motorized dispersed camping sites and the spur roads to those sites. Inclusion of these sites and designation of the spur roads that lead to them would allow for the necessary dispersal of campers without further natural resource damage. This will facilitate the Department's need to distribute hunting pressure, optimize big game harvest objectives, and meet game management goals. It will also facilitate the safe and enjoyable use of all forest resources. The Department requests that all previously disturbed campsites and the spur roads leading to them remain open in the proposed alternative. The "new" draft EIS excludes an exemption provision for persons that According the final Travel Management Rule, motor vehicle use 19 hold a valid grazing permit on the Tonto which was included in the exempted from designation includes “Motor vehicle use that is original draft. specifically authorized under a written authorization issued under Federal law or regulations” (36 CFR 261.13(H)). Grazing permits fall under this exemption. In compliance with R3 Supplement to Forest Service Handbook 2209.13 15.13b, legitimate motorized use, including cross-country access, needed for conducting activities required under term grazing permits will be authorized unless compelling natural and/or heritage resource issues such as those identified below require postponement or modification of the activity. I would suggest the following wording be added to the final EIS: Motor According the final Travel Management Rule, motor vehicle use 19 Vehicle Use for Livestock Permittees Motor vehicle use would allow exempted from designation includes “Motor vehicle use that is unrestricted vehicle and machinery access to holders of valid USFS specifically authorized under a written authorization issued under grazing permits on the Tonto National Forest. Unrestricted access is Federal law or regulations” (36 CFR 261.13(H)). Grazing permits fall necessary for normal maintenance, livestock management, permit under this exemption. In compliance with R3 Supplement to Forest infrastructure maintenance, improvements and repairs within the permit Service Handbook 2209.13 15.13b, legitimate motorized use, and may require travel within neighboring permits located on the forest including cross-country access, needed for conducting activities for management activities. This would allow permittees the necessary required under term grazing permits will be authorized unless access on an immediate basis without requiring any possible compelling natural and/or heritage resource issues such as those permits/approvals that may be required under the plan as currently identified below require postponement or modification of the activity.

193 Travel Management on the Tonto National Forest

Comment Letter Original Comment Text Forest Service Response Number written. It would also insure full access required to properly manage a permit within the permit itself and in neighboring areas when necessary (e. g., going after livestock that got off the permit). During the early phases of discussion on the proposed Travel According the final Travel Management Rule, motor vehicle use 1120 Management Plan, language within the proposed plan clearly exempted from designation includes “Motor vehicle use that is addressed grazing permittes use of the forest, off road and OHV travel. specifically authorized under a written authorization issued under The language basically allowed holders of valid permits off-road access Federal law or regulations” (36 CFR 261.13(H)). Grazing permits fall anywhere if needed to administer the permit. In the Draft EIS that under this exemption. In compliance with R3 Supplement to Forest language was deleted and I understand that the intent is to authorize Service Handbook 2209.13 15.13b, legitimate motorized use, OHV use as part of the AOI issued every year and not include a including cross-country access, needed for conducting activities permanent exemption within the final plan. I request the original required under term grazing permits will be authorized unless language be reinstated into the final plan for the following reasons: compelling natural and/or heritage resource issues such as those OHV and off road travel is often necessary BEYOND a permitte's own identified below require postponement or modification of the activity. permit/allotments. It is not unusual to have to travel on adjacent allotments to retrieve livestock or to get to portions of the original allotment. Inclusion of the original language would allow that without having to have written permission if the exclusion is not covered within the written AOI. - Inclusion of the original language would preclude every ranger district having to come up with the language necessary to enact an exclusion to the Plan therefore insuring uniformity within the Plan and not numerous exemptions worded differently! - It would insure complete access as needed to maintain/manage the permit without needing additional paperwork for unforeseen use of off-road travel. In short the forest would be better served by recognizing that permit holders have full rights under their lease to use the forest and equipment as needed without additional regulatory burdens which may result in inadvertent unlawful use of the country they steward. Many of the roads that go to range and wildlife improvements (waters) According the final Travel Management Rule, motor vehicle use 2405 are not in the database and will not even be open for "administrative exempted from designation includes “Motor vehicle use that is use". There are over a hundred FS wildlife waters on the Payson and specifically authorized under a written authorization issued under Pleasant Valley Ranger Districts and hundreds of new range stock Federal law or regulations” (36 CFR 261.13(H)). Grazing permits fall tanks that are not in FS data bases. under this exemption. In compliance with R3 Supplement to Forest Service Handbook 2209.13 15.13b, legitimate motorized use, including cross-country access, needed for conducting activities required under term grazing permits will be authorized unless

194 Volume II–Response to Comments

Comment Letter Original Comment Text Forest Service Response Number compelling natural and/or heritage resource issues such as those identified below require postponement or modification of the activity. This data needs to be included in this analysis or at least during the According the final Travel Management Rule, motor vehicle use 2405 implementation, allowing for motorized trail use on these roads and exempted from designation includes “Motor vehicle use that is motorized access for maintenance of the water developments. specifically authorized under a written authorization issued under Federal law or regulations” (36 CFR 261.13(H)). Grazing permits fall under this exemption. In compliance with R3 Supplement to Forest Service Handbook 2209.13 15.13b, legitimate motorized use, including cross-country access, needed for conducting activities required under term grazing permits will be authorized unless compelling natural and/or heritage resource issues such as those identified below require postponement or modification of the activity. With the OHV impact on the destruction of corrals, waters, pipelines, Comment is an opinion and lacks "supporting reasons for the 2520 fences, and other range improvements, it has made it uneconomical for responsible official to consider" per 36 CFR 218.2. No further us to graze cattle in these areas. We are working diligently with the response is warranted. Forest Service to develop a plan to graze the remaining units of

195