May 13, 2019 Travis Moseley, Forest Supervisor c/o Peggy Luensmann Lincoln National Forest Supervisors Office 3463 Las Palomas Alamogordo, NM 83310 Submitted online at: https://www.fs.usda.gov/project/?project=51146 Thank you for the opportunity to provide comment on the South Sacramento Restoration Project Draft Environmental Impact Statement (Draft EIS) on the Sacramento Ranger District of the Lincoln National Forest, New Mexico. Please accept these comments from the Center for Biological Diversity (The Center), WildEarth Guardians, Defenders of Wildlife, Western Watersheds Project, and the New Mexico Wilderness Alliance. The 45-day comment period plus 2-week extension ends on May 13, 2019, making these comments timely. Thank you for granting our request for an extension, as providing thoughtful and substantive comment on such a large and high-risk project is very important for us. The Center for Biological Diversity is a public-interest wildlife conservation organization that works to secure a future for all species. We do so through science, law and creative media, with a focus on protecting the lands, waters and climate that species need to survive. We provide these comments on behalf of our 1.4 million members and activist-supporters nationwide who value wilderness, biodiversity, old growth forests, and the threatened and endangered species which occur on America’s spectacular public lands and waters. WildEarth Guardians is a nonprofit conservation organization headquartered in Santa Fe, NM with offices in several western states. With more than 230,000 members and supporters WildEarth Guardians work to protect and restore wildlife, wild places, wild rivers, and the health of the American West. For many years, WildEarth Guardians has advocated for an environmentally and economically sustainable transportation system on Forest Service lands, with properly managed motorized recreation. Western Watersheds Project is a non-profit conservation group working to protect and conserve the public lands, wilderness, wildlife, and natural resources of the West through education, scientific study, public policy initiatives, and litigation. COALITION COMMENTS ON THE SOUTH SACRAMENTO RESTORATION PROJECT DRAFT EIS MAY 13, 2019 New Mexico Wild works for the protection, restoration, and continued enjoyment of New Mexico's wild lands and wilderness areas. Founded in 1997, it achieves its mission through administrative protection, federal wilderness designation, and ongoing stewardship of public lands, including those in the Lincoln National Forest. New Mexico Wild has a membership of individuals from all corners of New Mexico and across the nation. Defenders of Wildlife is a nonprofit organization with 1.8 million members and supporters across the nation, including nearly 20,000 in New Mexico. Defenders is dedicated to the protection of all native animals and plants in their natural communities. Defenders of Wildlife protects and restores imperiled species by transforming policies and institutions and promoting innovative solutions needed to conserve wildlife and habitat. Defenders has field offices across the country, including in Santa Fe, New Mexico. Some of our organizations members and supporters live in the South Sacramento Restoration Project area, and many more have enjoyed recreating and observing wildlife in the remarkable forests included in this project. Together, we stand united in our defense of wildlife and healthy ecosystems on our public lands, especially an area as biologically rich as the Sacramento Mountains. We support the active restoration projects in fire-adapted southwestern ecosystems insofar as they (1) follow science-based methods of strategically placing thinning treatments to facilitate the use of prescribed and wild fire for restoration; (2) reduce and do not add to existing road systems; (3) develop and describe in detail science-based monitoring and adaptive management systems; (4) meet the requirements of the National Environmental Policy Act (NEPA), Endangered Species Act (ESA), National Forest Management Act (NFMA), and in this case the Healthy Forests Restoration Act (HFRA); (5) follow core principles of forest restoration including the unambiguous retention of all large and old trees and forests; (6) utilize the best available site-specific scientific information for development of projects-specific desired conditions and natural range of variability; (7) develop management courses of action and prescriptions from relevant and recent field-based information; (8) maintain or increase protections for threatened, endangered, sensitive, or candidate species and roadless, unroaded or wilderness areas; and (9) address the impacts of livestock grazing on project success and ecological sustainability. While the South Sacramento Restoration Project makes steps in the direction of these shared objectives, our review of the Draft EIS leaves us concerned that the project still has a long ways to go before we can consider supporting it. For each of these criteria, the Draft EIS falls short. The comments in this letter explain in detail why we believe these crucial criteria are not being met and provides substantive recommendations for addressing areas of concern. 2 COALITION COMMENTS ON THE SOUTH SACRAMENTO RESTORATION PROJECT DRAFT EIS MAY 13, 2019 We truly appreciate the opportunity to provide our response to the Draft EIS, and we recognize the amount of work that has been invested to get to this point. Please keep us apprised of future opportunities for public commenting, attending field trips or collaborative workshops, and other ways to engage in the management of our public lands respective to this project and others o the Lincoln National Forest. We believe a meeting to discuss the concerns brought forward in the letter should happen as soon as you have had the time to thoroughly review it. Please let us know when that should take place. Respectfully yours, Joe Trudeau Edward B. (Ted) Zukoski Southwest Advocate Senior Attorney Center for Biological Diversity Center for Biological Diversity PO Box 1013 1536 Wynkoop Street, Suite 421 Prescott, AZ 86302 Denver, CO 80202 [email protected] [email protected] 603-562-6226 303-641-3149 Cyndi Tuell Adam Rissien Arizona & New Mexico Director Rewilding Advocate Western Watersheds Project PO Box 7516 738 N. 5th Ave, Suite 200 Missoula MT, 59807 Tucson, AZ 85705 WildEarth Guardians [email protected] [email protected] 520-272-2454 614-706-9374 Michael Dax Judy Calman New Mexico Outreach Representative Staff Attorney Defenders of Wildlife New Mexico Wilderness Alliance 210 Montezuma Ave, Suite 210 317 Commercial Street NE, Suite 300 Santa Fe, NM 87501 Albuquerque, NM 87102 [email protected] [email protected] 505-395-7334 505-843-8696 3 COALITION COMMENTS ON THE SOUTH SACRAMENTO RESTORATION PROJECT DRAFT EIS MAY 13, 2019 BACKGROUND: THE SOUTH SACRAMENTO RESTORATION PROJECT The objectives of the proposed action are to:1 Restore Forest and Ecosystem Health •Restore overall forest health, watershed health, and wildlife habitat. •Increase forest resiliency to insects, disease, and climate change. •Include all ecosystem types in the planning area: mixed-conifer, ponderosa pine, pinyon- juniper, meadows, aspen, and others. Reduce Wildland Fire Risks •Reduce high-severity fire risks to protect life, property, and natural resources by reducing crown fire hazard potential, and minimizing the potential of post-fire flooding. •Reduce the likelihood of human-caused ignitions. •Increase the ability of fire suppression crews to control and manage future wildfires. Improve Mexican Spotted Owl Habitat •Protect existing and promote development of future habitat suitable for nesting, roosting, foraging and dispersal to further recovery of the species. •Increase our understanding of the short-and long-term effects of land management on existing and future habitat. Improve Watershed Function •Improve soil condition and productivity where it is impaired. •Improve hydrologic function of springs and seeps. •Improve the quality of perennial and intermittent waters and riparian areas. These objectives are repeated on page 9 of the Draft EIS. The Draft EIS summarizes that: “The purpose of the project is to restore overall forest health, watershed health, and wildlife habitat for each ecological response unit in the project area. There is a need to increase forest resiliency to insects, disease, and climate change by shifting forest structure, composition, and diversity toward desired conditions within the historic (or natural) range of variability for each forest type. There is also a need to reduce risks of uncharacteristic wildfires and to improve species habitat and watershed conditions.”2 1 Based on the scoping letter of April 4, 2017, and the April 26, 2017 “Public Meeting Presentation and Handouts” available on the project website (https://www.fs.usda.gov/project/?project=51146). 2 Draft EIS at i. 4 COALITION COMMENTS ON THE SOUTH SACRAMENTO RESTORATION PROJECT DRAFT EIS MAY 13, 2019 In these comments we identify concerns with the Draft EIS from legal and scientific bases. We provide justification for our claims rooted in case law, agency regulations, federal code, and scientific literature. Where applicable we provide recommendations for improving analysis, proposed treatments, and expected outcomes. These are our principle objections to the Draft EIS: 1). The project does not meet the definition of a Healthy Forest Restoration Act