Forest Service releases public comments and postpones objection period for two months

Jonathan Glass   updated May 15, 2024

On April 29, the Forest Service pushed back its estimate of the start of an official objection period for its Encino Vista Project from May 1 to July 1.  That same week, the agency also finally released 89 public comments it received on the project’s draft Environmental Assessment (EA).  The Forest Service did not issue a news release for either event.  

An objection period starts after a comment period for a Draft EA only after an agency makes a determination of No Significant Impact and releases the following three items for public inspection:

♦  a Final EA, which will contain any final revisions to the Draft EA
♦  the agency’s responses to the public comments it received on the Draft EA (responses are either released as a standalone document or incorporated into the Final EA)
♦  a “Draft Decision Notice and Finding of No Significant Impact,” which includes the decision to proceed with the project, the rationale for proceeding, and an explanation of the agency’s determination that the project will not significantly affect the quality of the human environment

The Forest Service now has the option of doing none of that and instead preparing an Environmental Impact Statement (EIS) for the project.  There would be no imminent objection period in such a case.  However, given that the agency anticipates an objection period early this summer, it appears that it has already decided that an EIS is not required for Encino Vista.  In other words, America’s foremost forest management agency appears to be preparing to formally deny that its arguably largest cutting and burning project in Santa Fe National Forest history is likely to significantly affect the New Mexicans who live in and around the project area.  

During the objection period, which will most likely last for 45 days, anyone who previously submitted comments may object to the project based on issues they raised in such comments.  Objections are submitted to the Reviewing Officer who will be named by the Forest Service; this must be someone senior to the Responsible Official for the project (the Coyote District Ranger).  After the objection period, the Reviewing Officer will respond in writing to the objections and – depending upon the objections’ perceived validity – possibly instruct the Responsible Official to make clarifications and/or changes to the project proposal before issuing a Final Decision Notice.

The Forest Service estimates that such final decision will come on November 1. The agency’s tight timeline this year suggests that it expects to receive no objections which will cause it to substantially revise the project or to prepare an EIS.

Final Decision Notices are final in the sense that they leave objectors with no further possible administrative remedies from within the Forest Service.  After a final decision, a request for change to a project is generally adjudicated in federal court.

Recent Background

On March 14, the US Forest Service released new details about its Encino Vista project and offered the public a second opportunity to comment on its plans.  The new Draft EA proposes the cutting and/or intentional burning of up to about 82 thousand acres of forest. The stated purpose of the project is to “restore overall forest health, lower uncharacteristic high severity fire risk, improve watershed health, and protect wildlife habitat across the project area.”  However, many people living near the project area — as well a number of  conservation organizations — have questioned whether it is possible for the proposed project to achieve such purposes.  The total extent of public opposition to Encino Vista is unknown, because the Forest Service, for unclear reasons, has chosen not to release the public comments for public viewing.  

Since the Encino Vista Project was announced in 2019, the Forest Service has reduced by over thirty percent the total acreage proposed to be cut and/or intentionally burned within the project area.  However, the new proposal more than quadruples the maximum amount of area to be intentionally burned without first being cut; this is now about 48 thousand acres, which is more than half the total area proposed for burning. 

Another new addition to the agency’s proposal is commercial logging across over seven thousand acres. Through timber sales, the agency proposes to offer saw timber between 14″ and 24″ in diameter.  

Below is a map of the approximately 130-thousand-acre project area relative to the cities of Los Alamos and Santa Fe. The colored lines on the map are roads, many deteriorated, including 761 miles of forest roads within the 203 square mile Encino Vista area.  Most of the roads were constructed to facilitate decades-old logging operations.  The Forest Service now proposes to improve up to 500 miles of these roads to accommodate the logging trucks, masticators, and other heavy equipment that will be needed to implement the project.  

CLICK TO ENLARGE

Project Publicity

The Forest Service announced Encino Vista and a corresponding public scoping meeting about the project in November 2019 with a paper flyer which was posted locally and mailed to some post office boxes near the project area.  For further publicity about the scoping process, the agency issued no public news release, placed no legal notice in a newspaper, and contacted no news source to announce the project, even though Encino Vista was proposed to be the largest cutting and burning project in Santa Fe National Forest history.

The Forest Service received only 14 comments from the public during the 2019 scoping comment period for Encino Vista.  In contrast, also in 2019, thousands of people submitted scoping comments about the agency’s smaller but much better publicized cutting and burning project – the Santa Fe Mountains Project.  When in 2019, the Santa Fe National Forest Supervisor of the time went on public radio to discuss the Santa Fe project, he did not so much as mention the much larger Encino Vista project which the agency also had in the offing that year. 

Upon the release of its Draft Environmental Assessment (Draft EA) in March, the Forest Service finally issued its first news release ever on the project, placed a legal notice about the project in the Albuquerque Journal, and posted on its online project page most of the scoping comments which it received from the public in 2019.  The agency had chosen not to post the scoping comments online for public view at the time of scoping, and it continued not to post the comments for more than four years, including when the agency released its responses to the scoping comments in 2021.  Its stated position was that its posting public comments was an optional courtesy, as opposed to a requirement.  However, this policy appears inconsistent with Forest Service regulations governing public participation in land management planning, which state that

the agency should be “proactive and use contemporary tools, such as the Internet, to engage the public, and should share information in an open way with interested parties”

For unknown reasons, the Forest Service waited until April 29 to release the public comments it received on the Encino Vista Draft EA.  In the past, public comments submitted online about many other Forest Service projects have become immediately viewable in an online reading room.  By emailing the agency’s Region 3 Press Office, Public Journal tried to understand the decisions the agency made about handling the comments for Encino Vista:

PJ:  Why has the Forest Service not made the comments received from the public on the Encino Vista PEA available to the public?
USFS: The comment period for the Encino Vista Landscape Restoration Project ended April 15 and comments will be available to the public the week of April 29, 2024.
PJ:  In the past, the Forest Service has typically set up CARA (Comment and Analysis Response Application) so that public comments submitted to the agency via CARA are automatically posted in the online reading room for a project. Why was it decided not to have public comments on the Encino Vista PEA appear in the Encino Vista Reading room when they were submitted via CARA?
USFS: Posting public comments in the online reading room during the comment period is not a requirement of the NEPA process. Public comments will be available to the public the week of April 29, 2024.
PJ:  Why did the Forest Service not provide email as an option for submitting public comments on the Encino Vista PEA, as it has done for past SFNF projects?
USFS:  For the Encino Vista Landscape Restoration Project the Santa Fe National Forest accepted comments through CARA, by mail, and in person (hand delivery to Mark Sando, Coyote District Ranger).

A Question of Significance

Management of US forests is governed by the nation’s foremost environmental statute: the National Environmental Policy Act (NEPA).  Before a federal agency can implement a major project “significantly affecting the quality of the human environment,” NEPA requires preparation of an EIS about the environmental impact of what the agency proposes to do. 

An EA, such as the Forest Service has produced in draft form and released for the Encino Vista Project, requires a lesser type of analysis of impacts than is required in an EIS.  Under NEPA, the public comments received about a Draft EA are to help an agency assess a project’s impacts and decide whether it is required to prepare an EIS. 

Cañones Community Concerns

Santa Fe National Forest’s Cañones Vegetation Project, in development in early 2019, was designed to protect the Cañones watershed.  As the agency expanded that initiative into the much larger Encino Vista Project, members of the Cañones community became alarmed that their concerns about the project were not being heard.  Concerns included the possibility of escaped burns as well as the enormous amounts of flooding and sediment runoff that can occur during rainstorms, particularly after cutting and/or burning in the mountains above the village.

The Forest Service seems to have come to understand that it neglected Cañones in the scoping process.  In its October 2020 Encino Vista Scoping Comment Content Analysis, the agency wrote:

The Forest intends to hold several public meetings in Cañones to better understand needs and concerns that the community may hold. (p. 21)

In April 2024, when it was clear that the Forest Service was not even going to hold a meeting in Cañones before the end of its suddenly announced 30 day comment period on the draft EA for Encino Vista, community members in Cañones decided to hold a meeting of their own and invite the agency.  The Forest Service accepted the invitation.  On April 11, 2024, the Santa Fe National Forest Supervisor along with five forest officials attended a community meeting in Cañones.

At the meeting, the Forest Supervisor stressed that his top priority for Santa Fe National Forest – higher priority than any specific project – was to know and relate to local communities and to be a community asset.  The Supervisor said he heard the agency had “really missed the bar” during scoping and that they had work to do on the project which they did not get to.  “I’m hoping,” he said, “that this is the beginning of more of that dialogue with the community here in Cañones.”

The Coyote District Ranger, who is the Responsible Official for Encino Vista but did not hold that position at the time of scoping in 2019, also expressed regret about having “dropped the ball” in respect to community requests of the agency for more transparency and more meetings. “I take responsibility for that,” he said. “However, if I can somehow redeem myself a little bit, I am willing to do that.”

During the meeting, agency officials heard many concerns from the Cañones community, including about the hazard of choking smoke that descends into the canyon when there is fire in the area, about the single route available for evacuating from the canyon in case of an emergency, about the agency’s inadequate analysis of the Cañones Creek Watershed, and about the agency’s focus on industrial logging as opposed to small-diameter logging which community members have traditionally carried out in the area.

Toward the end of the meeting, the Forest Supervisor suggested that working collaboratively will help the agency not miss things.  Collaboration, he said, will enable the agency to address many questions and concerns and also help it prioritize communities and local operators.

In response to community members suggesting that the Forest Service must prepare an EIS for Encino Vista because of likely significant impacts of the project, the Forest Supervisor stressed that “significance” is a legal term defined by the Council on Environmental Quality (CEQ).  He said that the Responsible Official has to address ten questions, and that the responses determine whether a project’s impacts are significant.  “If you can describe why it’s not significant in response to those ten questions,” he said, “then you go to a FONSI, and if you can’t, then you go to an EIS.”

No Significant Impacts from the Santa Fe Mountains Project 

In May of 2023, the Forest Service issued a Final Decision and FONSI for its Santa Fe Mountains Project, which like Encino Vista is a wide-scale cutting and burning initiative announced by the agency in 2019.  The decision demonstrates how the agency considered the ten factors which the CEQ required for assessing the intensity of a project’s impacts as part of a final determination of significance.  Following are excerpts of the agency’s consideration of two of the CEQ significance factors regarding impact intensity (click the links to view the corresponding pages of the Decision). 

From USFS consideration of CEQ impact intensity factor #2 – The degree to which the action affects public health and safety.  Here, the agency provides no assessment of the probability of an “unplanned catastrophic wildfire” emerging from a planned burn that escapes control:
Due to the emphasis placed on safety in all federal fire management policies and the current NFS practice of using available resources to notify the public of fire management activities, Alternative 2 [the project’s Proposed Action] is not anticipated to impact public health and safety broadly. However, individual impacts may occur but overall impacts are not significant by mitigating impacts and advanced notices as compared to an unplanned catastrophic wildfire.
From USFS consideration of CEQ impact intensity factor #4 – The degree to which the effects on the human environment are likely to be highly controversial.  At least 97% of the thousands of people who submitted public comments about the Santa Fe Mountains Project requested an EIS.  Here the Forest Service asserts, without evidence, that not one of these commenters documented a substantial dispute about project impacts amidst their thousands of pages of disputes about project impacts:
During the public scoping process for the project, 7,426 scoping comments were received. All substantive scoping comments were addressed in the EA. In addition, 123 comment letters were received during the [Santa Fe Mountains Project] EA public review period. The U.S. Forest Service has determined that none of the comments provided during the public involvement process document a substantial dispute as to the environmental consequences of [the project].

How the Forest Service Gave a Comparable Project Far Greater Publicity

In 2012, the Forest Service planned its Southwest Jemez Mountains Project — a cutting and burning project beginning three miles to the south of the current Encino Vista area.  The Southwest Jemez project area at the time of its scoping was about fifteen percent smaller than Encino Vista’s at scoping.  The Forest Service produced the required Environmental Impact Statement for Southwest Jemez.

By the end of the public scoping comment period for  Southwest Jemez, the Forest Service had already held ten public meetings on the project – four in Santa Fe, four in Jemez Springs, and two in Albuquerque. The agency also invited the public on three field trips to the project area in the Jemez. The meetings and field trips were publicized with multiple news releases and by placing announcements in four newspapers and on public radio.

By contrast, by the end of the initial public comment period for Encino Vista in 2019, the Forest Service had held only two public meetings about the project – both in Gallina, New Mexico.  Furthermore, the agency has held no field trips for Encino Vista.  

Overall, it appears questionable whether the Forest Service has handled its Encino Vista Project in a fashion consistent with the Council on Environmental Quality (CEQ) regulation on public participation in effect at the time of scoping, which states that

Federal agencies shall to the fullest extent possible encourage and facilitate public involvement in decisions which affect the quality of the human environment.

Environmental Justice

The Forest Service has a responsibility under its regulation, “Requirements for Public Participation,” to provide opportunities for engagement about projects and encourage participation by low income and minority populations.  The Coyote Census County Division (CCD) of Rio Arriba County, New Mexico, encompasses the communities most proximate to the Encino Vista Project Area.  This area has less than half of the mean US household income, a poverty rate more than one and a half times the US average, educational attainment of less than half the US average, and households in which the majority speak a language other than English.  As a result, it appears that the amount of public outreach conducted by the Forest Service for the Encino Vista Project, including community meetings, field trips, media exposure, and news releases, would be expected to be much more – not less – than that for projects affecting areas of average demographic characteristics.

♦        ♦        ♦        

Project Photos

Key Project Details

♦  One of the two largest cutting and intentional burning projects ever proposed for Santa Fe National Forest: 
⇒  total project area of 130,305 acres in the northern Jemez Mountains
⇒  up to ~81,892 acres of cutting and/or intentional burning 
⇒  up to ~74,690 acres of intentional burning
⇒  up to ~47,990 acres of intentional burning without prior cutting
(why the terms “cutting” and “intentional burning”?)
⇒  up to ~33,902 acres of cutting, including 7,202 acres of commercial logging of 14″ to 24″ diameter saw timber via timber sales
⇒  up to 500 miles of road improvement
♦  Almost twice as much combined cutting and intentional burning than is slated for the Santa Fe Mountains Project (for which 18,000 acres of cutting and 38,000 acres of intentional burning is expected)
♦  Compared with the proposal in the 2019 scoping document, the current proposal entails up to about four times as much intentional burning without prior cutting, at least 25% less intentional burning overall, and at least 65% less cutting overall.
♦  According to Forest Service, “the project was developed based on the need to improve ecosystem and watershed resiliency and reduce the risk of uncharacteristic wildfire events to the surrounding communities.”
♦  Project area less than 40 miles from Santa Fe and less than 15 miles from Los Alamos

Key Documentation

♦  US Forest Service’s news release / invitation for public input about Encino Vista
♦  USFS’ online project page for the project
♦  USFS: Draft environmental assessment, Mar 2024
♦  USFS: Appendices to draft environmental assessment
♦  USFS: scoping notification letter, Nov 2019
♦  USFS: scoping document, Nov 2019
♦  The Forest Advocate: selected excerpt from each public scoping comment 
♦  The Forest Advocate: public scoping comments obtained under the Freedom of Information Act, Nov-Dec 2019 
♦  USFS: response to public scoping comments, Oct 2020
♦  Serious concerns and requests regarding the Encino Vista Project, a memo to Santa Fe National Forest Supervisor from community members and scoping commenters, including myself, Feb 2022

USFS’ Stated Purpose and Need

The draft environmental assessment defines the purpose and need of the Encino Vista Project as follows:
The Purpose of the Encino Vista Landscape Restoration project is to restore overall forest health, lower uncharacteristic high severity fire risk, improve watershed health, and protect wildlife habitat across the project area. In order to implement restoration activities and improve forest health, there is also a need to improve and maintain a transportation system in a manner that reduces negative impacts to watershed health and facilitates access to project areas.
The Need of the Encino Vista Landscape Project is to move the forest toward desired conditions, as described in the Santa Fe National Forest Land Management Plan (USDA, 2022b), protect local communities and watersheds, protect and enhance wildlife habitat, and create a resilient forest landscape that may withstand unforeseen disturbances.

Public Open Houses about the Project

Hosted by US Forest Service
On Thursday, March 14, 2024, USFS announced open houses:
Wednesday, March 20, 2024
5:30 p.m. to 8:00 p.m
Coronado High School Boardroom
1903 State Highway 96, Gallina, NM
public attendance: 4
Saturday, March 23, 2024
1:00 p.m. to 3:00 p.m.
Location: Rural Events Center – Abiquiu
House #122A State Road 55, Abiquiu, NM
public attendance: 5

Composite Project Maps

USFS Project Maps

Note on Terminology

The word “cutting” is used on this site to describe cutting down trees in the forest, whether with chainsaws, masticators, or other machines which cut and/or shred live vegetation.  The Forest Service generally uses the word “thinning” to describe its cutting practices, even if it is cutting down most of the trees in an area.
The term “intentional burning” is used on this site to describe intentionally setting an area of forest on fire.  The Forest Service typically instead uses “prescribed burning” to describe such practice, or — particularly in past years — “controlled burning.”  Because intentionally set fires can escape control, and because the word “prescribed” commonly connotes medical treatment which is beneficial to life, “intentional burning” seems like the clearest descriptor here.
Note that agency documentation typically refers to the collective practices of cutting and intentional burning as “fuels treatments” and/or “restoration.”
For more on the language of forest management, see an article by Sarah Hyden in Counterpunch.

The Public Speaks

The majority of public commenters on the Draft Environmental Assessment for the Encino Vista Project believe that the Forest Service should prepare an Environmental Impact Statement (EIS) for the project.

Of the 89 public commenters, 8 express direct support for the project itself, and 6 express support for at least one goal of the project, but not for the project itself.  The remaining commenters express support for neither the project nor its goals. 

The selected excerpts below link to the respective complete comments.  

“Please undertake a thoughtful and informed EIS — it will go a long way in easing the minds of the public and easing my mind. An EIS has a social component and economic component which have not been addressed.”

“The land speaks a timeless wisdom, and the heart intuitively knows that the proposed plan is shortsighted.  In New Mexico, there is a strong feeling of ‘tierra sagrada’; that we live on holy land. It is deep in the blood of Norteños, and for outsiders to come in and show irreverence toward what is sacred to the local community is a sad story which has long been told in the Americas.”

“The landscape does not lend itself to this type of prescribed burning project. The Northern New Mexico Stockman’s Association 100% opposes this project.”

“If you really want to do something significant in forest fire prevention, how about replacing a lot of power lines with underground lines, as so many fires begin from lines sparking and windblown snags breaking transition lines.”

“I’m in favor of thinning and logging the Encino Vista Restoration Project and piling brush to be burnt which creates a healthy forest for the future.”

“Please do not follow through with this proposed project… New Mexico has endured too many escaped Forest Service burns that have severely damaged our forests and left our citizens with trauma and loss of homes, lives and environment. We cannot endure another.”

“The evident lack of effort to appropriately involve and inform the public is so extreme that it amounts to deliberate secrecy, and… would certainly be a justification for legal action to force compliance… we will do whatever is necessary to be sure that the Forest Service respects our rights!”

“Taking the “we know best” approach regarding maintaining these treasured lands has obviously not gone to plan in the past, and that truly brings up questions of environmental justice for all those living in these to-be-affected communities.”

“We agree with the purpose and need for this project… management actions proposed in the Encino Vista Draft EA can improve watershed function, reduce the risk of catastrophic wildfire, and benefit fish and wildlife species.”

“The lack of reverence that has been shown to the earth for the past couple centuries has resulted in an ecological catastrophe of which we have dug a hole too deep to climb out. Let us stop this destructive trend now, and listen to the earth.”

“This approach is not working. We are watching in horror as one of our most precious resources is pillaged… The Forest Service is responsible for the most destructive and out of control fires in the history of our state due to incomplete, incompetent or blatantly careless fire policies.”

“The EA acknowledges socioeconomic challenges of our community includes lower access to vehicle transportation and lower income. Yet, the few community meetings offered were in Gallina and Abiquiu, with no virtual option.”

“Shouldn’t it be “three strikes you’re out” on the SFNF for the level of destruction you have wrought on this forest and northern New Mexico? Maybe give us a pass on any further fire… rather than go full speed ahead with exactly the same problematic approach and mindset?”

“While the communities in Northern New Mexico are aware of the possible benefits of prescribed burns in maintaining a healthy forest, there is work that the U.S. Forest Service must do FIRST to restore trust, to prove that they can perform such burns without creating another catastrophe.”

“My husband and I have… explored in the Jemez Mountains for about 50 years. We have seen many changes to the forest and its management… We have seen forested areas with shade and understory reduced to individual trees and weedy, invasive vegetation due to “forest resiliency” treatments… it is depressing to picture what will be left standing and think of these cooler, shaded areas becoming exposed to the harsh sun and wind.”

“Your plans to start major fires and log mature trees for the Encino Vista Project illustrate the insanity of doing the same action while expecting a different result. This is a costly, deadly, mistake you are trying to embark all of us on – and almost completely outside of the public eye, since you did not fulfill your public communications duties to this Project.”

“I personally feel, as do most of my friends, that you are on the wrong track with your forest thinning and controlled burns.  Your actions are a statement that you know more than Mother Nature, and you’re going impose your faulty judgment on the forests and mountains of Northern New Mexico.”

“While the entire planet is trying to repopulate trees, you are looking at mass destruction for no reason…   The loss of life of old growth trees, animals, birds, insects, plants, other wildlife and people will be unfathomable through all this fire as well as all smoke you will be creating. This is an immoral and unethical project.”

“I support the proposed Encino Vista Landscape Restoration Project.”

“Please stop this project… You refuse to save the big old trees. You make slash piles that are a danger for long periods of time. Your burns are not effective. The cutting causes too much CO2 to be released.”

“Local observations indicate more frequent and more intense wind events over the past 2 years, relative to the past 40-50 years. Do the models being relied upon for decision making accurately reflect this?”

“My family and I attended the public meeting in Abiquiu and Forest staff continually said there isn’t enough staffing or funding when I asked why there aren’t more timber sale units, why so much area is planned for prescribed burn and why roads are such a limiting factor to them for improving these plans… I recommend seeking smaller operators from the local area.”

“I watched in horror as the escaped burn resulted in Hermits Peak/Calf Canyon Fire, a conflagration that destroyed homes and landscape and livelihoods… The Forest Service can never give back what it has taken away, but it can stop making the same mistakes now.”

“We generally support the goals of this project and appreciate that the SFNF has incorporated Project components aimed at improving and maintaining the transportation system to prevent erosion and damage to watersheds and other sensitive resources… The Project will help accomplish these goals.”

“It’s evident that the Encino Vista Landscape Restoration Project overlooked crucial steps outlined in NEPA, hindering community participation in the shaping of the environmental assessment. NEPA’s framework is designed to ensure informed decision-making and community empowerment through thorough transparent processes. The absence of local governance involvement during the preliminary phase raises significant concerns about the thoroughness of the project’s review.”

“The analysis and data is incomplete and done by staff with little awareness of local culture. There is lack of opportunity with local tree harvesters in favor of prescribed burning. The project too big for the budget and staff involved. The project needs to be done via the EIS (Environmental Impact Statement) process with more local analysis. We want additional research and investigation.”

“A clear pattern of escaped prescribed burns exists in New Mexico, some with catastrophic consequences, and conditions are getting warmer and drier which increases the probability of escaped prescribed burns..”

“The smaller trees this EA calls un-marketable at <12” diameter, and calls for mastication or burning of, are often the size for useable traditional building materials that the SFNF Land Management Plan and this Draft EA frequently claim will be made accessible and available to traditional community members.”

“We are writing in support of the Proposed Action… The detrimental direct, indirect, and cumulative effects of the No Action Alternative… are severe, would stray from direction outlined in the 2022 Santa Fe National Forest Land Management Plan, and, if no action is taken, would have a significant long-term impact… doing nothing is unacceptable.”

“I did not receive notice about this project and only found out about it a week ago from another community member who took it upon themselves to let others of us know. I would have liked to attend a presentation from someone speaking local Spanish to better understand this project.”

“I think the Forest Service has lost its way with regard to supporting biodiversity and using our national forests as a carbon sink to help climate change… These are aggressive proposals that seem to have no regard for the wildlife that lives in these tracts of land. I oppose the “restoration plan.”

“We support the Encino Vista Project’s objectives of restoring fire, enhancing wildlife habitat, and improving watershed resiliency. However, the Preliminary EA proposes a project that contains actions contradictory to those objectives, including logging some of the largest remaining trees in the area, reducing forest stands to extremely low tree densities, continuing livestock grazing that undermines the ability to restore fire regimes.”

“Your actions will have long term detrimental impact on the ecosystems of Northern New Mexico for trees, wildlife, and people.  I am sorry that you are so set on your plans and faulty strategy.”

“The proposed area for timber sale is currently very small relative to project area,,,  whereas the SFNF Land Management Plan sets targets of 10-40% timber harvest… For this Project, there need to be many more smaller sized timber sale units available to smaller, local operators. There needs to be less area designated for thinning / burning treatment.”

“I am a 71 year old woman with a masters degree. The forest is a magical and beautiful place that is home to many creatures, small and large, whose habitats will be destroyed. Precious lives will be lost and for something that is unnecessary and excessive. This hurts my heart. Please, please reconsider.”

“Any meeting of fire with forest results in dehydration – and not just to trees and vegetation that is burnt, but to all vegetation and soil: heating dries out these systems, in a phenomenon referred to in Australia as ‘fire follows fire.’”

“I’m in favor of the Encino Vista Restoration Project if it is going to be thinned, logged and the brush piled to be burnt to reduce the smoke. Which creates a healthy and productive forest for future generations.”

“I’m writing to strongly object to the Encino Vista project… Clearing the forest and opening the canopy will only result in hotter, drier conditions that will devastate wildlife and increase the threat of wildfire.”

“SFNF was told in public comment that many Cañones community members primarily speak Spanish. However, project materials have not been readily provided in Spanish, and the notification they are available by request is only embedded within the English language document.”

“More thought and attention is given to mitigating trail user impact along the Continental Divide Trail (CDT) than the entirety of the Cañones Creek watershed that will impact an entire traditional community.”

“The USFS in its recent efforts on the Santa Fe National Forest, has not only failed, but proved instead that prescribed burning under conditions of drought and climate change weather, will start the very megafires their technique claims to protect.”

“The Encino Vista EA contains numerous data presentation errors and arithmetical errors that preclude the public from adequately analyzing the project and making informed substantive comments.”

“I appreciate the project goals of reducing the risk of uncharacteristic and devastating wildfire in the project area… However, I have serious concerns with this project planning, the information being relied upon for decision making, and the lack of meaningful involvement of traditional communities, Acquia organizations, land grant Organizations, minorities and low-income residents beyond Tribes and Pueblos.”

“Humans do not have the right to just take and take and take… Set aside your belief in yourself… and look at the real picture. Look at the forest, and the trees. Please.”

“The most impaired watershed in the Project area, Cañones Creek, is not directly analyzed. Instead, the EA analysis includes only Coyote Creek as a proxy for all others, while being smaller and less complex than Cañones Creek and with much less agricultural acreage dependent upon it. This is inadequate.”

“Uncertain times call for precaution. From the Dog Head masticator fire in the Manzanos to the Hermits Peak escaped prescribed burns, we must learn from the past and not just do bigger prescribed burns as the ‘remedy.’”

“NMOHVA generally supports… [the Proposed Action… We strongly support active management of the SFNF as it is the only practical way for the USDA Forest Service… to significantly move the Forest towards its Desired Conditions.”

“The agency’s assumptions that reducing tree densities and fuel loadings will result in less intense fire behavior is controversial.  Fuel treatments may not tend to reduce the occurrence of high severity fire in a changing climate with extreme fire weather overriding on-the-ground  treatments. The reduction of all combustion on the planet is necessary to slow down and  hopefully stop the planet’s climate catastrophe.”

“In my view, there are clearly significant impacts to the human [and broader] environment that will be caused by this project. As you are aware, this is the criteria to proceed to further analysis through an Environmental Impact Statement (EIS).”

“The massive scale of this proposal does not convince me that enough attention is being paid to the specifics of the local areas that will be affected. Cañones is a small, rural, agricultural community. A project of this scale has the potential to seriously impact people’s livelihoods, health, and welfare.”

“As a member of the Cañones community and the Monastery of the Holy Archangel Michael located therein, I feel the risk of wildfire too great a burden to justify the measures being taken. The air quality will compromise our health, as fires nearby have done before… The Forest Service is not respecting the sacredness of the land, and I feel a loss in my soul because of the destruction of the land…  May God give us the grace to have courage to reconsider this plan.”

“The New Mexico Energy, Minerals and Natural Resources Department-Forestry Division is submitting this letter of support to the United States Department of Agriculture, Santa Fe National Forest Service’s Encino Vista Landscape Restoration Project in the Jemez Mountains.”

“The Forest Service must do a Health Impact Assessment that addresses the human health effects of your proposed burning. The Forest Service must also do an Environmental Impact Statement (EIS), because the project proposes to radically alter the environment, which clearly will have a significant impact on it.”

“It is not adequate to have “meeting regulatory requirements” for prescribed burn emissions as a goal when a substantial number of residents living near agency ignited prescribed burns have reported that smoke exposures from burns often make them ill, and some report being confined to their homes with air filters during prescribed burns, resulting in loss of income, loss of the ability to carry out activities related to basic responsibilities and needs, and loss of enjoyment of life.”

“I feel that the current proposal has inadequately taken into account the residents of Rio Arriba County and its environs. There are many elderly people in the area of the proposed project. It is not clear to me where they will be able to go when the dense smoke from the fires begins blow in. Many such people are in poor health, and will not be able to travel.” 

“”The prescribed burning USFS does is the opposite of cultural burning in almost every way, and Forest Service indoctrinating people in “Fire is good now” mentality, using cultural burning as a starting point, is disingenuous and misleading.”

“The Albuquerque Bernalillo County Water Utility Authority is expressing its support for the United States Department of Agriculture, Santa Fe National Forest Service’s Encino Vista Landscape Restoration Project in the Jemez Mountains.”

“Please Do NOT BURN DURING THE SPRING, both the Cerro Grande Fire and the Hermits Peak fires were prescribed burns that happened during the windiest part of the year. Please Please Please refrain from burning on windy days. Please  refrain from burning in the spring.”

“At the very least, you need to conduct a proper Environmental Impact Statement, rather than just attempting to hurry this project along and elude public scrutiny!  I will be in touch with my Congressional Representative.”

Encino Vista Project
Public Comments on Draft EA

Note that two comments posted by the Forest Service were received by the agency after the April 15 deadline: one dated April 19 from the New Mexico State Forester, and the other dated April 30 from the Albuquerque Bernalillo County Water Utility Authority. Both comments are supportive of the project.