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Opportunity to Protect Wild Lands along AZ/NM Border!

Gila National Forest Draft Forest Plan Public Comment Period

The Gila National Forest (GNF) is accepting comments regarding its Draft Forest Plan which will dictate how the GNF will be managed for years to come. The White Mountain Conservation League and Wild Arizona (Arizona Wilderness Coalition & Grand Canyon Wildlands Council) are sending this alert to their volunteers and members. Public comments must be filed by April 16th - this Thursday. Both the White Mountain Conservation League and Wild Arizona are working with dozens of groups to submit comprehensive and highly technical comments (over 300 pages and growing) that cover a number of conservation issues. However, your heart-felt comments could be very helpful in influencing this process. So PLEASE spend some of your "sheltering time" submitting comments that will hopefully influence this very important decision.

We prepared and submitted comments regarding the GNF Plan that are specific to some potential wilderness units that straddle the Arizona/New Mexico state line. These untis are uniquely important since the Apache Sitgreaves National Forest deferred their decision regarding Arizona's portions of those units until after the Gila National Forest has completed their Revised Forest Plan. In 2018 over 20 volunteers from the White Mountain Conservation League and Wild Arizona took part in an inventory project that evaluated the wilderness potential of these units. Our comments can be viewed via the attachment to this email and are also pasted below. You will note that many key talking points that you may find helpful are highlighted, but also be sure to include why protecting these particular places is important to you! Please don't feel overwhelmed, but prepare your comments as technical or as general as you like. I personally believe that comments specific to these areas, and particularly from Arizona and White Mountain residents, will be very helpful. Thank you and stay well!

Electronic comments are preferred via the comment analysis and response application (CARA). Enter your comment by going to the CARA link immediately above, or selecting the "how to comment link" on the project webpage. In the CARA online form enter your contact information and either add your comment directly into the text box, or upload a letter or form by selecting attachment; ensure you hit submit when you are done.

Three Potential Wilderness Units that straddle the Arizona/New Mexico state line. (These units share acreage managed by the Apache Sitgreaves National Forests.)

The Apache Sitgreaves National Forests has completed their Forest Plan Revision Process, but it did not make any recommendation regarding the Mother Hubbard, Nolan Canyon or Hell Hole potential wilderness units. Instead the Apache Sitgreaves National Forests deferred their decision regarding these units until the Gila National Forest conducted their Forest Plan Revision process. The opening page for each of these units in the Apache Sitgreaves National Forests Potential Wilderness Evaluation Report indicates: "A decision as to whether or not to recommend this area for wilderness will be deferred until the Gila National Forest completes its Potential Wilderness Evaluation and Land Management Plan Revision."

The Gila National Forest is widely respected because of its heritage of protecting and managing wild places. Certainly the Apache Sitgreaves National Forests will respectfully consider the Gila National Forest's decisions recommending potential wilderness units that straddle the state-line boundary. Currently less than 1 per cent of the Apache Sitgreaves National Forests is congressionally designated as wilderness - perhaps the lowest of any National Forest.

1. Comments regarding Mother Hubbard Canyon Unit: (ASNF 2100 acres; GNF 6090 acres)

We appreciate that the Gila National Forest Wilderness Evaluation Report found this area to have an over-all rating of "High". The Apache Sitgreaves National Forests used different (now obsolete) evaluation criteria than did the Gila National Forest. However the Apache Sitgreaves National Forests Potential Wilderness Evaluation Report indicates "High" values for its "capability" and "availability" to provide wilderness values.

• The Mother Hubbard unit is highly sought by hikers and horse users for its scenic vistas, wildlife viewing and hunting opportunities. All of the ridges separating the various tributary watersheds within this unit offer "outstanding scenic" viewing to the east, south and west. (Photo above)
• The Mother Hubbard unit contains perhaps the most significant waterfall feature (a "special geologic" feature) on the entire Gila National Forest. It is located on the New Mexico side within Pace Creek. In fact, back in the 1970's the Bureau of Reclamation proposed the construction of a hydro-electric plant at the base of this series of waterfalls and grottos hundreds of feet tall. The proposal was abandoned due to the potential environmental impacts associated introducing water pumped from geothermal wells, thus raising the water temperature in Dry Blue Creek to over 100 degrees Fahrenheit.
• There are numerous (dozens known) prehistoric and historic cultural sites (special features) within the Mother Hubbard Canyon unit including large Mogollon pueblos and historic cabin sites.
• The existence of the geologic feature (series of waterfalls), cultural features and scenic features were accurately provided during the public comments period regarding the draft Potential Wilderness Evaluation Report. Those documented comments should have easily elevated the ranking to outstanding in the "special features" category during the potential wilderness evaluation process.
• Finally we believe that the natural appearance rating should have been elevated to a much higher rating in the Final Potential Wilderness Evaluation Report. The fact that the unit is bound on the east side by an ORV trail certainly should not affect the natural rating of the lands within the unit. In fact all designated wilderness and IRAs tend to be bounded by unnatural features - it is what identifies the boundaries of those areas. The short ORV intrusion from Dry Blue into Pace Creek is very minimal and could easily be restorable or cherry stemmed and should not be used to devalue the highly natural appearance of the entire interior of this unit. There are no trails within the entire unit and the off-trail hiking provide outstanding opportunities to enjoy solitude in a highly "natural" appearing environment. Please elevate the ranking regarding natural appearance.
• Mother Hubbard Canyon (along with Frieborn Canyon) provides important habitat for the Mexican Wolf Recovery Project. Wolf sightings are numerous in both the Arizona and New Mexico portions of the unit. In 2018, the Mother Hubbard Canyon unit provided a successful denning site for the Mexican gray wolves. Providing remote and wild lands within prime wolf habitat helps to reduce human conflicts and certainly supports outstanding ecological value of this potential wilderness unit.
• The Mother Hubbard Canyon unit is highly regarded for providing excellent habitat to a growing Bighorn Sheep population. In 2019, the Arizona Game and Fish Department continued to transplant Bighorn Sheep into the area. The hunting permits issued for this herd unit represent the most highly prized hunting opportunities in Arizona further supporting the outstanding ecological values of this potential wilderness unit.
• There is no suitable commercial timber within the Mother Hubbard Canyon unit (in Arizona and new Mexico) and the topographic ruggedness of this unit makes this area equally unsuitable to any type of motorized access. The New Mexico portion has been in perpetual non-use by livestock since 1995. The outstanding opportunities for solitude, high scenic values, outstanding geologic, cultural and ecological values provide strong support for managing Mother Hubbard Canyon as a potential wilderness unit as its highest use.

2. Comments regarding Nolan Canyon Unit: (ASNF 6640 acres; GNF 12,200 acres)

We appreciate that the Gila National Forest Wilderness Evaluation Report found this area to have an over-all rating of "High", though we believe it should have ranked higher. The Apache Sitgreaves National Forests used different (now obsolete) evaluation criteria than did the Gila National Forest. However the Apache Sitgreaves National Forests Potential Wilderness Evaluation Report indicates "High" values for its "capability" and "availability" to provide wilderness values.

We can understand why the Nolan Canyon unit was divided into two units (north and south) on the New Mexico side as they are only connected by roadless lands in Arizona that are managed by the Apache Sitgreaves National Forests. We would hope that the Apache Sitgreaves National Forests will concur with the Gila National Forest that the entire unit has a "High" or greater rating for potential wilderness. Currently less than 1 per cent of the Apache Sitgreaves National Forests is congressionally designated as wilderness - perhaps the lowest of any National Forest.

If the final Gila National Forest is compelled to evaluate the North and South Nolan Canyon areas as separate units, then we suggest that you rename the North unit to "Frieborn Canyon" and maintain the "Nolan Canyon" label for the southern unit. Our specific comments regarding the Nolan Units are as follows:

• We believe that the Special features category should be elevated to "Outstanding" based on a few features. There is a very unique prehistoric cave dwelling directly adjacent to Frieborn Creek. The Owl Fire in 2018 resulted in significant flooding in Frieborn Canyon. However the dwelling with its surviving masonry walls remains largely intact even though flood waters related to the Owl Fire have hit it hard. It is a relatively challenging site to travel to. This is a very significant site of "historical value".
• The Nolan Canyon South unit also exhibits numerous high elevation pueblo sites, many distant from what are now the perennial water sources. These cultural sites are scattered fairly consistently along the flats from the Saddle Mountain Road to the east where the Nolan canyon breaks steeply into the Blue River Canyon.
• Frieborn Canyon, which occurs entirely within the Nolan North unit, demonstrates significant scenic and geologic features which should also elevate the "Special Features" ranking. There are numerous slot canyons within the trail-less sections of Frieborn Canyon that are extremely scenic and offer outstanding opportunities for solitude and primitive recreation. As a result of flooding related to the Owl Fire, some of the slots have been plugged with logs over 10 feet deep in rafts backing 100's of feet upstream making hiking highly interesting and at times challenging.

  
  Frieborn Canyon hike
  soot line from Owl Fire is visible
  
  

• Frieborn Canyon (within the Nolan Canyon North unit), like the Mother Hubbard Canyon unit, is an important habitat for the Mexican Wolf Recovery Project. Wolf sightings are numerous in both the Arizona and New Mexico portions of the unit. In 2017 the Mother Hubbard Canyon unit provided a successful denning site for the Mexican gray wolves. Providing remote and wild lands within prime wolf habitat helps to reduce human conflicts and certainly supports the outstanding ecological value of this potential wilderness unit.
• The Frieborn Canyon trail (a developed trail all within the New Mexico portion of the Nolan Canyon North unit) and the Nolan Canyon trail (a very primitive trail mostly in Arizona and terminating on the Blue River) both provide exceptional opportunities regarding primitive recreation and solitude.
• The upper reaches of Frieborn Canyon (within the Nolan Canyon North unit) is representative of an extraordinary old-growth stands of Mixed Conifer and Ponderosa Pine with many trees exhibiting diameters of 48 inches or greater. A post Owl Fire hike found that a majority of these old growth stands along the drainage bottoms survived the fire.
• There is no or very little accessible commercial timber within the Nolan North or South units (in AZ or NM) and the topographic ruggedness of this unit makes this area equally unsuitable to any type of motorized access. The New Mexico portion in the Nolan Canyon North unit has been in perpetual non-use by livestock since 1995. The outstanding opportunities for solitude, high scenic values, outstanding geologic, cultural and ecological values provide strong support for managing the entire Nolan Canyon unit (but especially the Nolan Canyon North unit) to protect wilderness values and clearly represents its highest use.

3. Recommendation regarding the adjacent Mother Hubbard Canyon and Nolan Canyon Potential wilderness units.

We emphatically ask that the Gila National Forest identify both the Mother Hubbard Canyon and Nolan Canyon units as areas recommended for Wilderness in the Final Revised Land Management Decision. Both the units received the same score based on the criteria used, yet only the Nolan Canyon North unit was included within the Preferred Alternative - perhaps thinking it was a compromise to competing interests. However, we strongly believe that managing these two adjacent units in concert to protect their wilderness character would increase the wildland benefits many fold.

• Managing both the Mother Hubbard Canyon and Nolan Canyon units (particularly the Nolan North unit) to protect their wilderness values would effectively offer protection to the entire perennial Dry Blue watershed including Dry Blue Creek, Pace Creek, Coyler Creek and the entire Frieborn Canyon.
• Managing both the Mother Hubbard Canyon and the Nolan Canyon units in concert to protect their wilderness values would enhance their overall "ecological" value. The lower end of Dry Blue Creek is designated critical habitat for loach minnow. Additionally in 2017, Mexican gray wolves denned in Frieborn Canyon in 2017 and 2018. There was also a den site and significant wolf signs within the Mother Hubbard Canyon unit. These represent very important wilderness values that should be protected.
• Many local and adventuresome residents along the Arizona/New Mexico state line place a premium on the backcountry opportunities provided by these two potential wilderness units. The White Mountain Conservation League therefore places a high priority on the protection of the wilderness values of these two units.
• Two wilderness units separated only by an ORV trail corridor represent a very unique opportunity for the public user. It allows for motorized off-road travel and camping along the highly scenic Dry Blue Creek. Off road users prize the opportunities where they too can travel and camp adjacent to wild environs far away from the open road network. It is rare when Forest Service officials can make a decision that can simultaneous satisfy the needs of both the ORV user and Wilderness advocate communities. In fact, we believe this rare combination would present a great opportunity for the Gila National Forests to tout a decision that respects the interests of often opposing user groups.
• The Apache Sitgreaves National Forests has deferred their analysis of Nolan Canyon unit until after the Gila national Forest has completed its Land Management Planning process. By recommending both the Nolan Canyon North and South units for future wilderness in the Gila National Forest Plan final decision the Gila National Forest will allow the Apache Sitgreaves National Forests to consider the option of keeping the original Roadless Area intact and managed as it has been primarily managed since the 1970's. As stated above, the Apache Sitgreaves National Forests intends to complete their decision process regarding these two areas "until the Gila National Forest completes its… Land Management Plan Revision".

4. Comments regarding Hell Hole Unit (ASNF 15,479 acres: GNF 20,535 acres)

The Gila National Forest Wilderness Evaluation Report found this area to have an over-all rating of "moderate, but which we believe should have ranked higher. The Apache Sitgreaves National Forests used different evaluation criteria. However, the Apache Sitgreaves National Forests Potential Wilderness Evaluation Report indicates "High" values for its "capability" and "availability" to provide wilderness values.

• The New Mexico portion of the Hell Hole unit provides the best access to the Arizona portion managed by the Apache Sitgreaves National Forests. Both the New Mexico and Arizona portion offer outstanding opportunities for primitive recreation and solitude. In particular, the steep canyons dropping off into the Arizona side offer spectacular scenery. It is important that these two portions be evaluated as one large 36,000 acre unit which together has a very high wildland value.
• The Hell Hole area along the Arizona-New Mexico state-line is south of Highway 78. The northern area of the proposed wilderness area, closer to Highway 78, is dominated by rolling hills while the southern area has deep canyons with sheer cliffs.
• The vegetation is highly variable with diverse riparian trees found in the bottom of the drainages while the hills are a mix of pinyon-juniper and grasslands, determined by the areas elevation and/or aspect. There are interesting stands of dwarf or stunted ponderosa on many of the northern slopes.
• This area has outstanding opportunities for solitude and primitive recreation and the likelihood of encountering other people is low except near the bordering roads.
• The area has very high scenic value with its deep canyons, soaring cliffs, and rolling grass covered hills. Varied wildlife abounds mainly in the drainages with a mixture of diverse bird life throughout.
• The southern area is adjacent to the BLM's Wilderness Study Areas, Hoverrocker and the Apache Box, which greatly enlarges the wilderness features and value of the area.

Recommendation: The Hell Hole area should be a recommended for wilderness in the Gila National Forest Plan.

Thank you for your support of our wild lands and waters in Arizona.