GAME AND FISH DEPARTMENT

Transcription

1 THE STATE OF ARIZONA GAME AND FISH DEPARTMENT 5000 W. CAREFREE HIGHWAY PHOENIX, AZ (602) GOVERNOR OOUGLAS A. DUCEY COMMISSIONERS CHAIRMAN, JAMES R. AMMONS, YUMA JAMES 5. ZIELER, ST. JOHNS ERIC S. SPARKS, lljcson KURT R. DAVIS, PHOENIX EDWARD "PAT" MADDEN, FLAGSTAFF DIRECTOR TYE. GRAY DEPUTY DIRECTOR TOM P. FINLEY January 3, 2018 Tonto National Forest Tonto Plan Revision Team 2324 East McDowell Road Phoenix, Arizona Re: Tonto National Forest's Preliminary Proposed Land and Resource Management Plan Dear Plan Revision Team: The Arizona Game and Fish Department (Department) has reviewed the Tonto National Forest's (TNF) Preliminary Proposed Land and Resource Management Plan (PPLRMP) dated November, The Department currently participates as a cooperating agency and interdisciplinary (ID) team member for the development of the Land and Resource Management Plan and greatly appreciates the collaboration and close working relationship with TNF on this project. The Department provides the following comments on our continued overarching concerns and line specific comments on the PPLRMP in the attachment. Species of Conservation Concern and at Risk The Department reiterates the importance of including the Species of Greatest Conservation Need (SGCN) and Species of Economic and al Importance (SERI), as identified in the Arizona State Wildlife Action Plan (SW AP), within the revised plan as species of conservation concern (SCC). The Department understands some SGCN and SERI species may be included within the identified Species of Conservation Concern and at Risk species; however, some are not and the Department requests the sources of this list be clearly identified. Including SGCN and SERI in the National Environmental Policy Act (NEPA) analysis is important because impacts to all wildlife resources will have to be disclosed. Further, all relevant information available for a reasonable alternative(s) to avoid and/or minimize those impacts, conservation and/or mitigation in those alternatives, must meet overall multiple use objectives, etc. (42 U.S.C 4332 (c) (i) and (iv), 40 CFR , 40 CFR (1), 16 U.S.C 1604(f)(l), 16 U.S.C. 1604(g)(3)(B)). In addition, within the Master Memorandum of Understanding between our agencies, the Forest Service agrees 'To recognize and give full consideration of the State's fish and wildlife species of concern and their habitats, including Species of Greatest Conservation Need, federally listed species, and the U.S. Forest Service designated species, and to treat these fish and wildlife populations as desirable and co-equal with other resources on the National Forests under the multiple resource management concept of the U.S. Forest Service' and 'To coordinate efforts that ensure continued conservation of the State's fish and wildlife species of concern, including Species of Greatest Conservation Need, Species of Economic and al Importance, federally listed species, and U.S. Forest AN EQUAL OPPORTUNITY REASONABLE ACCOMMODATIONS AGENCY

2 Tonto National Forest's Preliminary Proposed Land and Resource Management Plan January 3, Service designated species. ' The Department offers to work with the TNF through the drafting process to ensure a full and reasonable analysis of SGCN and SERI species. Special Designations and/or Management Areas The Department supports public land use that provides Arizona's public and resources with a net benefit and does not support the conversion of public lands from multiple use to designations or management areas that would result in a net loss of wildlife resources, wildlife related recreational opportunities and wildlife dependent economic benefits. The Department understands that the TNF is proposing at least one new special designation under the plan revision and at the PPLRMP public meetings encouraged the public to think about and suggest possible other special designation areas. The Department is concerned as to how the Lakes and Rivers Management Areas, and any of the potential special designations resulting from public input would impact multiple use of public lands, wildlife related recreation, and wildlife management activities. A full analysis of impacts including cumulative of further loss of public lands for multiple use, wildlife related recreation and wildlife dependent economics will be needed in the NEPA. The Department would like to work further with the TNF to ensure any proposed special designations and/or management areas (including those previously identified by the Department, ie. wilderness, wild and scenic, etc.) would not impact our ability to fulfill our mission and state trust responsibilities to manage fish and wildlife resources. Arizona's Hunting and Angling Heritage The importance of Hunting and Heritage under the forest resources identified in the PPLRMP and within the plan components is not well represented. As previously stated in the May 22, 2017 letter from the Department, the importance of the hunting and hunting heritage must be considered and evaluated per the Executive Order The Department recognizes one of the forest resources identified is the Hunting, Fishing and Wildlife Viewing and this information is represented and integrated into the plan components; however, we would like to work with the TNF to further identify where this should be represented and addressed within the other forest resources as well. The Department appreciates the opportunity to continue to participate throughout the planning, development and NEPA processes to provide data and expertise. If you have any questions or need more information about this letter and/or comments, please contact Kelly Wolff-Krauter at kwolff Krauter@azgfd.gov or Sincerely, ~~ ~~ Joyce Francis Habitat, Evaluation and Lands Branch Chief Cc: Laura Canaca, Project Evaluation Program Supervisor Jay Cook, Regional Supervisor, Mesa JMF:kwk Enclosures: PPLRMP AGFD Page-specific Comments

3 ARIZONA GAME AND FISH DEPARTMENT COMMENT MATRIX Preliminary Proposed Plan Comments Tonto National Forest Plan Revision TNF Preliminary Proposed Plan Department Comments Watersheds Criteria and guidelines are mentioned but it is still not clear how these Riparian and Water Management Zones were delineated.. Please identify how and why these areas were Resources delineated. Clarify how this special designation/allocation impacts public access and state wildlife management activities. Watersheds While it is clear that 10 springs during a 10 year period will be improved and/or maintained; and Water it is not clear as to the how these areas would be identified. We suggest including Resources specifically, the development or redevelopment of springs for wildlife benefit as part of that identification process. Wildlife, This section should also reference how these lists were developed as there were many lists from other agencies considered, evaluated with criteria and reviewed by the RO for the final list and this may continue to evolve as species ' status changes, scientific information becomes available, etc. Wildlife, The "significant risks" that desirable non-native species could pose to native species must be defined and include how those risks are measured and how this could be implemented. Wildlife, Any of the guidelines that include species under agreements and/or ESA should be looked 60 at as standards instead of guidelines. Wildlife, It should be made clear as to who would be consulted when determining measures needed to protect rare and endemic species, i.e. internal or external agencies. This should reflect the AGFD as one of the agencies. Wildlife, We request rewording this to say, "Permit conversions to domestic sheep and goats should only be permitted in those areas not historically or currently inhabited/travel by bighorn sheep and in consultation with the AGFD." 1 of 5

4 TNF Preliminary Proposed Plan Department Comments Wildlife, The discussion is very vague as far as species that could be sensitive to this change, it seems that at-risk species would all be sensitive; therefore, clarification as to how it will be determined which species are sensitive to impacts of climate is recommended. Invasive and It needs to be made clear in this section how the FS defines invasive, undesirable and Undesirable 63 nonnative. The section starts out by describing "invasive" but never describes that Species specifically as "undesirable" yet the second paragraph starts with "Another category of undesirable species includes..." What is deemed "undesirable" should be defined first and then the definitions of the types of species that are considered undesirable (i.e. invasive and noxious weeds) should follow. It needs to also be made clear that just because a species may be nonnative, that this does not necessarily mean it is undesirable. The terms "non-native, invasive" and "invasive" seem to be used interchangeably throughout this section. If the forest is considering these to be distinctly different from one another, then it needs to be stated. If they are considered the same, as the definition of "invasive" provided suggests, then only the term invasive should be used throughout this entire section. Proposed language: "There are two distinct categories of undesirable species found on the forest. The first category of undesirable species is an invasive species. A species is considered invasive if... The second category of undesirable species is a noxious weed. Noxious weeds are defined as..." Developed The use of permits and reservation systems should be identified and considered in consultation with AGFD as a management approach. Identify potential impacts to the AGFD mission and ability to manage wildlife. Developed In order to increase opportunity for the public to recreate, we suggest a change to: "Provide for multilingual interpretationforest-wide and look for opportunities to partner with local communities. Provide information in both English and Spanish, prioritizing this aooroach in recreation areas popular with Spanish-speaking visitors." Developed 76 The management approaches should include that information for the public includes any 2 of 5

5 TNF Preliminar y_j>rflposed Plan Department Comments PPP I Page I Line I Comment Dispersed Dispersed pertinent laws and restrictions on the forest. One of the identified desired conditions is dispersed recreation areas should provide visitors with natural, tranquil settings. This desired condition is subjective and uses wilderness characteristic descriptions (natural); potentially limiting otherwise compatible, lawful uses (OHV use, high use hiking, recreational shooting, etc.) Recommend removing these descriptors from the desired condition. The guideline (it is not clear as to the source of the guideline) restricting dispersed camping 100 ft from water resources should not be a blanket rule/restriction as some places have been mitigated for such or could be or and other places may have very little effects. Currently, there is no federal restriction for dispersed camping near water sources except in designated facilities near water (Haigler Canyon Campground, Canyon Creek Campgrounds). There is a state law (17-308) that prohibits camping within¼ mile of "a natural water hole containing water or man-made watering facility" in a manner that denies access to the "only reasonably available water source". The intent of this state law is to restrict camping within ¼ mile of point water sources. This does not include riparian areas or large bodies of water (lakes) with long reaches of available water for wildlife or livestock. The intent of this new riparian area guidance (and the 100 foot rule) is to keep people away from the critical/sensitive 100 feet surrounding riparian areas that would have unintended consequences resulting in unnecessary restrictions to camping around large bodies of water like Saguaro, Canyon, and Roosevelt Lakes and/or remotes stretches of river/streams where dispersed camping is likely not causing damage (e.g. folks floating down the upper Verde River and upper Salt River and camping within 100 feet). It remains unclear as to the guidance for the new lakes and rivers management areas if there will be an additional buffer and how that buffer will be defined. Dis_.2_ersed We request the mitigation process be defined and that it includes an option for permit zones 3 of 5

6 TNF Preliminary Proposed Plan Department Comments to be considered as an alternative to full closure. This approach has proven successful in the past. Dispersed Law enforcement should be mentioned as a management approach. al The definition of recreational shooting should include any shooting that is carried out in a Shooting legal and safe manner, does not cause resource damage and does not result in litter (as previously suggested by the AGFD comments on the NOi) Motorized Clarify using the specific language from the Travel Management Plan, "Routes and areas not designated for motorized use will be prohibited from motorized travel unless authorized under an exemption in the Travel Management Regulations". Motorized The reference to recreational shooting being restricted and/or prohibited discusses a minimum of 1/4 mile from lakes and rivers special management zones. Clarify how these areas are delineated and identify the potential impacts on recreational shooting opportunities, public access, and wildlife management. Include a full definition of what a high use area is and how potential restrictions will be interpreted. Motorized Clarify this according to the Travel Management rule, "once roads, trails and areas on the Tonto National Forest have been designated and identified on the MVUM, motor vehicle use off the designated system is prohibited." Motorized This statement should be removed for its redundancy. Motorized Management approaches need to include exploring options for establishing new OHV areas and permit zones. Hunting, This needs to be reworded to say, "The public has expressed an interest in more opportunity Fishing, for native sport fishing." Watchable Wildlife Hunting, 84 This should be added as a desired condition: create more opportunities that focus on Fishing, Watchable education and conservation through wildlife viewing. 4 of 5

7 TNF Preliminarv Proposed Plan Department Comments Headin2 Wildlife Hunting, The public has expressed interest in more emphasis on watchable wildlife in this section. Fishing, We request the FS work with the AGFD in developing more guidelines and management Watchable approaches directed towards watchable wildlife. These could include language that Wildlife discusses working with AGFD specifically, to incorporate programs on the TNF for this purpose, along with the education and information initiatives and signage. Roads The use of nonnative species to either invasive or undesirable depending on the definition needs to be clarified in this section. Roads Prioritization of road decommissioning and trails should be in coordination with other agencies such as AGFD. Lakes and 119- This section needs to be fully analyzed for impacts to recreational activities. Rivers 121 Management Area 5 of 5