USDA Draft Revised Forest Plan (FP)

Citizen Action New Mexico Comments

April 16, 2020

Adam Mendonca

Forest Supervisor

Gila National Forest

3005 E. Camino del Bosque

Silver City, NM 88061


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Citizen Action New Mexico is a 501 (c) (3) Project of the New Mexico Community Foundation with environmental concerns for radiation and chemical contamination throughout the State of New Mexico.  Citizen Action requests an additional 90 days extension for review of the FP due to the impact of the Covid-19 on our research staff and resources. 

The Forest Service Draft Revised Forest Plan (FP) discusses several ecological, economic and social challenges for the Gila National Forest.  The Forest Service has historically allowed serious unsustainableovercutting of forests and the use of herbicides that sacrificed ecological considerations to commercial interests of logging, grazing and hunting.  Unfortunately, that bias toward commercial interests is still present in the revised FP and should be changed more favorably toward protection of the Gila National Forest environment.  Citizen Action strongly opposes the inclusion of the Silent Spring plan to use 21 herbicides for chemical management in a setting that includes several endangered species and numerous wildland-urbaninterfaces.

Notably, while there is FP discussion of climate change impact on e.g., water, species and fire, there should be accompanying discussion for how management plansfor the reduction from the impact of ongoing and proposed human activities necessary to protect the forest.  The vulnerability to climate change requires consideration of reduction of damage to the ecosystem by limitingor reducing the level of ongoing human activities orexpected increases in

  • stream clogging road construction,
  • commercial tree cutting,
  • vehicle traffic,
  • mining,
  • fires,
  • hunting of animals and foraging for plants,
  • recreational activities,
  • utility corridors, etc.

Details should be provided e.g., for how much motorized new road construction is anticipated for mining claims, corridors for utility and microwave transmission, increased grazing herd levels, for allowable tree cuts and how such impacts can be avoided or eliminated.

There should be discussion regarding what limits will be set in place for human activities so that the forest can return to its historical level of density for trees, vegetation and species.  A correlated problem is that there is no baseline given for what those historical levels were for differing environmental categories of tree density and species levels so that it is unknown what are the quantifiable levels to be set asreasonable targets for recovery.  Discussion of supporting ecological features in the FP is appreciated.

There should be a presentation of a specific commitment and management plan not to engage in logging or fuel wood gathering, road construction, livestock grazing, herbicide use or any other activity that further threatens endangered species such as the Mexican Spotted Owl,Mexican gray wolf within the Gila. While the endangered and threatened species are listed as various points throughout the FP it is unclear what the management plan is to actually protect these species from human activities. 

There should be an in depth FP discussion of what would represent a sustainable level of forest harvest for

  • different use categoriesfor the units as a whole and with respect to other national forest in New Mexico
  • varying climate change levels that can be expected for water and
  • increased fires from climate change induced drought.

The Forest Service plans for large-scale commercial logging in southern New Mexico’s Lincoln National Forest are less than reassuring that the Gila NF will be given protection from excessive logging activities.The discussion in the FP section Timber Harvest is less than encouraging that overcutting in the Gila will not continue well beyond its regeneration capacity and that old growth forest will be maintained.  The FP states:

“… [T]here will always be challenges. However, they will not be insurmountable if there is collaboration and cooperation between Gila managers, State Forestry, and local governments.”

There is no statistical presentation of what management considers the allowable cut to bethat could sustainably be made while bringing the forest back to historical levels.  There needs to be more than vague reassurance.

The FP jumps to an expansion from present day cultural local firewood “gathering” to “Using commercial fuelwood harvest as a restoration tool.” The FP should set forth an explanation of why the firewood process should now cater to unknown commercial interests, their magnitude or how forest restoration would thereby be accomplished by commercial harvest.  Consideration of illegal taking of trees should be considered.

How an increase in tree density will be accomplished needs to be discussed in relation to each of the various categories of human use such as tree harvesting, firewood gathering, grazing activities, road construction, mining, etc.  The impact of current timber removal methods needs attention with respect to topsoil loss.  There should be discussion of how the different tree and vegetation species use will be balanced so that the forest does not simply become skewed toward production of a particular type of commercial species with the ensuing reduction of quantity and size of species that may possess that commercial value.  The use of herbicides is particularly suspect in that regard where forest species are wiped out for monoculture forestry. 

A separate Programmatic EIS should be developed and considered separately from the Forest Plan for consideration ofthe use of 21 herbicides.As an attorney, I can assure that the inclusion of the FP plans for herbicide usage in such broad strokes constitutes grounds for a lawsuit.  The FP approach that “On the Gila NF, all the tools are ‘in the toolbox,’ ” for herbicides needs to be fully ventilated and dismissed before the FP proceeds. Herbicides pose:

  • Particularly toxic effects and risks for the fetus, infants, children and many species of flora and fauna including endangered and threatened species are in evidence from herbicide use.
  • The FP pretense of “monitoring and adaptive management,” fails to define what, when, or how monitoring of herbicide use would proceed, or how management would adapt to adverse results.
  • The toxification of the Gila ecosystem should be avoided and
  • Primary consideration instead given to human management and employment.
  • Recent studies of the use, for example, of Roundup have resulted in a $250,000,000 cancer lawsuit settlement against their manufacturers. The jury award was originally for $2 Billion.
  • 2, 4 D is relatively persistent in anaerobic (low oxygen) aquatic environments (half-life ranges from 41 to 333 days). This has implications for fragile wetland areas, especially those under conservation.
  • Dicamba is highly mobile in the soil and does have the potential to contaminate ground or surface water. Dicamba can drift and damage Gila NL species.
  • Hermaphroditic, demasculinzed frogs have resulted from exposure to the Department of Agriculture approved use of the herbicide Atrazine.
  • Whether there is contemplateduse of fire suppression chemicals containing perfluoroalkyl substances (PFAS),human-made chemicals which have been linked to cancer,is not discussed in the FP. PFAS have been destructive to groundwater resources, destroyed entire lakes (Lake Holloman) and riparian areas, and endanger fire fighters.
  • Mists from herbicide sprays on hot days can drift for miles in high winds and result in damage to nearby crops.
  • Runoff from treated areas may impact algae, aquatic organisms, and fish.
  • Careless cleaning of equipment can contaminate soil, ground and surface water, and desirable vegetation. Proper transport, storage, disposal and spill procedures are not described in the FP.
  • Off-site application can occur if boundaries are not clearly marked and applicators are not aware of their location.

The FP overemphasizes the significance of hunting activities without providing any statistics that compare the educational, economic and ecological benefits of hunting with non-hunting uses of the forest.There is no reason, other than license fees, that non-hunting education and appreciation of forest diversity cannot be encouraged instead of the FP excessively touting hunting. 

The FP demonstrates bias in baldly saying that “Hunting … provides food, bonding opportunities between parents and children, and can be used to teach children about nature and natural lands.”  No other balancing statement is provided anywhere that children could be possibly be even better educated about nature and conservation of natural lands by means other than killing animals!My son is a field biologist specializing in endangered species identification and directing habitat renewal projects.  We didn’t kill any animals along the way although we ate a hellish amount of mushrooms.

In fact, the following graphs from the National Survey of Fishing, Hunting, and Wildlife Associated Recreation (FHWAR) that has been the gold standard for decades and conducted every five years chronicle the steady decline of hunting both nationally and in New Mexico compared with wildlife watching participants.(New Mexico and other states were not surveyed in 2016 for revenues).  As can also be seen in the graphs below, there are substantially more participants, greater expenditures and economic impact, jobs, salaries and wages, state and local taxes generated by Wildlife Watching compared to Hunting. Hunting participation on New Mexico has reduced from 15% to 10% participation. Data sources:





FHWAR New Mexico Participation 1991

FHWAR New Mexico Participation 1996

FHWAR New Mexico Participation 2001



FHWAR New Mexico Participation 2006


FHWAR New Mexico Participation 2011



New Mexico Hunting license data


There should be FP recognition of and the quantification of the positive economic impact of the non-hunting recreational users with respect to achieving restoration and protection of the forest. Theabove statistical presentation for the different uses of the forest and those activities should be weighted in favor of forest and species preservation.

Overhunting of apex species is a particular problem throughout the western United States.  While the revenue from the sale of hunting licenses may be desirable from an agency standpoint, the revenue from recreational activities, e.g., hiking, wildlife and bird watching, photography, kayaking, etc., to local business and taxing authorities far exceeds the revenue from hunting licenses.  The problem of bias is thereby created in the absence of a reasonable funding mechanism for wildlife agencies and the overloading of agencies with commercial grazing, logging and hunting interests.

There should be adequate attention given by the FP to the presence of the apex predators, notably mountain lion, bear and wolves.  While there are 25 FP references to hunting, there is only one mention of mountain lion and black bear with no details as to the ecological importance or protection of those species. There is no inventory presented for the apex species. (Inventories are grievously lacking for other species as well).  The mountain lion and black bear are only mentioned in reference to hunting (p. 102) as if their sole importance is to be gunned down:

“People enjoy high-quality hunting, fishing, and wildlife viewing in the Gila NF. All of the native big game species in the state occur in the forest: black bear, bighorn sheep, elk, javelina, turkey, mountain lion, pronghorn, mule deer, and white-tailed deer.“

The Forest Service should consider the importance of the apex predators in the context of their contribution to control of species that can overrun the forest and damage riparian areas especially ungulates associated with grazing as well as feral domestic species.  Damage to streambanks in the Gila NF from the irresponsible grazing of domestic animals needs much further enforcement control or elimination.  The experience in Yellowstone National Park with restoration of riparian areas by the re-introduction of the wolf population is instructive. 

While the Mexican gray wolf is mentioned as an endangered species, there seems to be no real consideration of how the Mexican Gray Wolf, the New Mexico meadow jumping mouse, Mexican Spotted Owl or other endangered species will be protected from adverse human activities.  It is unacceptable for the FP to merely present that the protection of endangered and threatened species constitute a “management problem” with no thought or presentation as to solutions. Then, inthe next sentence the FP promotes restoration projects as having the goal of meeting local demand for forest products:

“[P]rotection of endangered and threatened species can pose range management challenges. Forest restoration and landscape-scale restoration projects can help sustain forest and watershed health, and maintain the ability to sustainably meet local demand for forest products.”

The local demand for forest products is not quantified however. 

Livestock and Wildlife Conflicts.The lack of protection of the Mexican Gray Wolf is egregious and winked at by the U.S. Fish and Wildlife Service and the Department of Agriculture.  The FP needs to have a realistic discussion about halting the trapping, poisoning and shooting of wolves as if only the cattle industry is of importance.  This again is bias in favor of commercial cattle interests and lack of protection while giving lip service in a FP document. 

Memos obtained in March 2020 by the Center for Biological Diversity are evidence that the “U.S. Fish and Wildlife Service surreptitiously authorized the killing of four endangered Mexican gray wolves in New Mexico on behalf of the livestock industry.” The U.S. Department of Agriculture’s Wildlife Services program killed one wolf on March 23 and three more on March 28.“Scientists have long recommended that ranchers be required to clean up or render inedible (i.e. by applying lime) the carcasses of cows that die on their watch in order to prevent wolves from being drawn to the proximity of vulnerable livestock. Yet the Fish and Wildlife Service opposes making such measures mandatory to prevent predation on stock.Ranchers are allowed to graze their private livestock on public lands with little accountability.”

The riparian corridors suggested for wild and scenic river protection of 450 miles are far too limited by half.  Utility corridors, microwave corridors, transportation corridors, trail corridors and alternative energy sites are discussed.  The amount of expected area of land to be used for these corridors is not set forward with respect to quantification for loss of habitat from road building and destruction or interference with sensitive habitats.  There should be planning for protection and development of corridors for animal movement to other wildlands or national forests. Corridors for large animal movement is not set forward except in the riparian context.  

The Forest Service should adopt the wilderness recommendations in Alternative 5 for 150,000 total acres rated as Outstanding by the Forest Service itself.  The amount of wilderness recommended in the FP is without justification for only 46,685 acres which is only 31% of what is Outstanding.

Please acknowledge receipt of these comments.

Respectfully submitted,


David B. McCoy, J.D., Executive Director

Citizen Action New Mexico

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