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United States Department of Agriculture Forest Service Southwestern Region August 2009 Environmental Assessment: Mormon Mountain Communications Site Coconino National Forest
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Page 1: Mormon Mountain Communications Sitea123.g.akamai.net/7/123/11558/abc123/forestservic.download.akamai... · The proposed project is needed to provide additional tower space for FM

United States Department of Agriculture

Forest Service

Southwestern Region

August 2009

Environmental Assessment:

Mormon Mountain Communications Site

Coconino National Forest

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The U.S. Department of Agriculture (USDA) prohibits discrimination in all its programs and activities on the basis of race, color, national origin, age, disability, and where applicable, sex, marital status, familial status, parental status, religion, sexual orientation, genetic information, political beliefs, reprisal, or because of all or part of an individual’s income is derived from any public assistance program. (Not all prohibited bases apply to all programs.) Persons with disabilities who require alternative means of communication of program information (Braille, large print, audiotape, etc.) should contact USDA’s TARGET Center at (202) 720-2600 (voice and TDD). To file a compliant of discrimination, write to USDA, Director of Civil Rights, 1400 Independence Avenue, S.W., Washington, D.C. 20250-9410, or call (800) 795-3272 (voice) or (202) 720-6382 (TDD). USDA is an equal opportunity provider and employer.

Printed on recycled paper – August 2009

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Environmental Assessment for Mormon Mountain Communications Site, Coconino NF i

CONTENT

Summary ....................................................................................................................................................... 1

Chapter 1 – Purpose and Need.................................................................................................................... 3 1.1 Document Structure ...................................................................................................................... 3 1.2 Background................................................................................................................................... 3 1.3 Purpose and Need for Action ........................................................................................................ 6 1.4 Proposed Action............................................................................................................................ 7 1.5 Decision Framework ................................................................................................................... 12 1.6 Public Involvement and Scoping ................................................................................................ 12 1.7 Issues Identified from Scoping.................................................................................................... 12

Chapter 2 – Alternatives ............................................................................................................................ 14 2.1 Alternatives ................................................................................................................................. 14 2.2 Alternatives Considered and Eliminated From Detailed Study ................................................. 15 2.3 Mitigation Measures ................................................................................................................... 15

Chapter 3 – Affected Environment and Environmental Consequences ................................................ 18 3.1 Past, Present, and Reasonably Foreseeable Future Activities ..................................................... 18 3.2 Earth and Water Resources ......................................................................................................... 19 3.3 Biological Resources................................................................................................................... 20 3.4 Land Use ..................................................................................................................................... 29 3.5 Socioeconomics .......................................................................................................................... 32 3.6 Environmental Justice ................................................................................................................. 34 3.7 Visual Quality ............................................................................................................................. 34 3.8 Cultural Resources ...................................................................................................................... 37 3.9 Air Quality .................................................................................................................................. 37 3.10 Noise ........................................................................................................................................... 38

Chapter 4 - Consultation and Coordination ............................................................................................ 40

Chapter 5 - References............................................................................................................................... 41

Chapter 6 – List of Preparers.................................................................................................................... 42 USDA Forest Service, Coconino National Forest.................................................................................... 42 Northland Research, Inc........................................................................................................................... 42

Figures Figure 1. Vicinity Map. .......................................................................................................................... 4 Figure 2 – MMCS location and proposed boundary. .............................................................................. 8 Figure 3 – Control Survey depicting existing and proposed facilities................................................... 10 Figure 4 – Propagation Map.................................................................................................................. 11

Tables

Table 1. Existing tower facilities at the MMCS. ..................................................................................... 5 Table 2. Forest Service sensitive species analyzed. .............................................................................. 23 Table 3. Summary of MIS habitat in the project area............................................................................ 24 Table 4. Anticipated effects to MIS under the proposed action. ........................................................... 25 Table 5. Inventory of larger trees and snags within the MMCS site boundaries. .................................. 29

Photos Photo 1. View as seen from FH-3 at Lake Mary. (Photo dated 10/20/08)........................................... 35 Photo 2. View through zoom lens from FH-3 at Lake Mary showing towers on mountain top horizon.

(Photo dated 10/20/08) ................................................................................................................. 36 Photo 3. View from Mormon Lake Overlook. (Photo dated 10/20/08)............................................... 36

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Environmental Assessment for Mormon Mountain Communications Site, Coconino NF 1

Summary

The Coconino National Forest (CNF) is considering a proposal to change communication site management on Mormon Mountain to allow for taller towers and to authorize vegetative treatments to reduce the threat of wildfire damage to communications facilities. In addition there is a specific proposal by DW Holdings LLC to construct a communication tower and support facilities for use by wireless telephone providers. Mormon Mountain Communications Site (MMCS) is located southeast of Flagstaff, Arizona on the top of Mormon Mountain on the Mormon Lake Ranger District.

The proposed project is needed to provide additional tower space for FM radio broadcast; improve wireless personal communication services in Northern Arizona, principally southeast of Flagstaff along the Forest Highway 3 (FH-3) corridor and the community of Mormon Lake where such services are not currently available and/or reliable; and to protect communications facilities from wildfire. Communications sites must be designated in the Forest Land Management Plan (LMP). Forest Service policy requires that every site have a communications site plan that provides management guidance and development constraints. There is a need to adjust tower height limitations at MMCS by allowing taller towers to address additional tower space needs of both high power broadcasters and wireless users.

This EA presents the results of an analysis of the direct, indirect, and cumulative environmental consequences of the proposed action and no action.

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Environmental Assessment for Mormon Mountain Communications Site, Coconino NF 3

Chapter 1 – Purpose and Need

1.1 Document Structure The Forest Service has prepared this Environmental Assessment in compliance with the National Environmental Policy Act (NEPA) and other relevant federal and state laws and regulations. This Environmental Assessment discloses the direct, indirect, and cumulative environmental impacts that would result from the proposed action and alternatives. The document is organized into five parts:

• Introduction: The section includes information on the history of the project proposal, the purpose of and need for the project, and the agency’s proposal for achieving that purpose and need. This section also details how the Forest Service informed the public of the proposal and how the public responded.

• Comparison of Alternatives, including the Proposed Action: This section provides a more detailed description of the agency’s proposed action as well as alternative methods for achieving the stated purpose. These alternatives were developed based on significant issues raised by the public and other agencies. This discussion also includes possible mitigation measures. Finally, this section provides a summary of the environmental consequences associated with each alternative.

• Environmental Consequences: This section describes the environmental effects of implementing the proposed action and other alternatives. This analysis is organized by environmental component. Within each section, the affected environment is described first, followed by the effects of the No Action Alternative that provides a baseline for evaluation and comparison of the other alternatives that follow.

• Agencies and Persons Consulted: This section provides a list of preparers and agencies consulted during the development of the environmental assessment.

• Appendices: The appendices provide more detailed information to support the analyses presented in the environmental assessment.

1.2 Background Mormon Mountain Communications Site (MMCS) is an existing communications site designated as such in the Coconino National Forest Land Management Plan (CNFLMP) located on the top of Mormon Mountain approximately 25 miles southeast of Flagstaff, Arizona (Figure 1). MMCS has been in existence since 1969 when the first TV broadcast tower was constructed. MMCS is located at NW1/4SW1/4 Sections 1 & 2, T18N, R8E, Gila and Salt River Base Meridian. The site is the only Forest Service location designated for high power TV and FM radio broadcast in the Flagstaff area. High power broadcast has been given priority at this site by the existing and approved MMCS Communications Site Plan, however low power users are also using the location. The site has experienced steady growth in response to the FCC issuing additional licenses for TV and FM broadcast to serve an increasing area population and currently encumbers an area approximately 11.7 acres in size. The site currently is occupied by seven towers (Table 1) and associated buildings and a National Resource Conservation Service (NRCS) Snotel station. The FS has responded to this growth by authorizing additional facilities and allocating additional land for communications site purposes.

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4 Environmental Assessment for Mormon Mountain Communications Site, Coconino NF

Figure 1. Vicinity Map.

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Environmental Assessment for Mormon Mountain Communications Site, Coconino NF 5

Table 1. Existing tower facilities at the MMCS. Tower No. Base Elevation (feet) Top of Antenna Elevation (feet) Tower Height (feet)

1 8,479.9 8,764.3 284.4 2 8,454.5 8,713.8 259.3 3 8,457.4 8,752.8 295.4 4 8,470.5 8,671.3 200.8 5 8,470.1 8,618.6 148.5 6 8,470.5 8,670.4 199.9 7 8,469.7 8,665.5 195.8

The wireless communications industry (cell phones) has also expanded tremendously since the early 1990s. The general public now expects and relies on wireless service for cellular telephones to be available in most places. The wireless industry first focused on providing service in metropolitan areas and major transportation corridors. The industry is now developing facilities in more rural areas like Mormon Lake and arterial type highway corridors like Forest Highway 3 (FH-3). The FH-3 corridor and the community of Mormon Lake have areas where wireless personal communication services are not currently available and/or reliable.

The Forest Service has been given direction from Congress and the President to facilitate implementation of the Nation’s strategy for wireless communications. On August 10, 1995, President Clinton released a memorandum entitled “Facilitating Access to Federal Property for the Siting of Mobile Services Antennas.” In this memorandum, the following is stated:

Upon request, and to the extent permitted by law and where practicable, executive departments and agencies shall make available, Federal Government buildings and lands for the siting of mobile service antennas.

On February 8, 1996, the Telecommunications Act of 1996 was enacted, giving further direction to Federal agencies. In response to the memorandum and the Telecommunications Act, the General Services Administration released a bulletin listed in the Federal Register on June 16, 1997, titled “Placement of Commercial Antennas on Federal Property.” This bulletin provides general guidelines and processes for implementation of President Clinton’s memorandum. Regarding granting of siting requests, the bulletin states:

Requests for the use of property, right-of-way, and easements by duly authorized telecommunications service providers should be granted unless there are unavoidable conflicts with the department’s or agency’s mission, or current or planned use of the property or access to that property.

This EA will analyze the impacts of constructing a wireless telecommunication site at MMCS, the impacts of allowing taller towers within the area designated for communication uses, and the impacts of vegetation treatments to reduce the threat of damage or destruction of communications infrastructure and equipment from wildfire.

According to the Forest Land Management Plan map, the proposed action is located within Management Area (MA) 4. MA 4 contains 32,677 acres and is made up of ponderosa pine and mixed conifer on slopes greater than 40 %. Recreation and wildlife are the major uses of the mixed conifer.

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6 Environmental Assessment for Mormon Mountain Communications Site, Coconino NF

General management direction in the CNFLMP for communications sites is to minimize the number of electronic sites and utility corridors consistent with appropriate pubic services that can only be met on Forest lands and to administer special uses to best meet public needs.

MMCS is a communications site designated in the CNFLMP, open to private and government users. The site is currently used by commercial high power broadcast, 2-way radio, wireless, and microwave. High power FM radio and TV broadcast is given priority by the Forest Service at this site by the management direction and objectives specified in the approved Communications Site Plan.

1.3 Purpose and Need for Action The purpose and need for action is defined by four separate existing conditions as follows:

1. There is a need for additional tower space at MMCS. MMCS is an important and valuable high power broadcast communications site. The site accommodates all of the high power FM radio and television broadcast stations for the Flagstaff area. The wireless telecommunications industry continues to expand in response to public demand for those services resulting in the need for additional facilities at MMCS. It is anticipated that the FCC will continue to issue new licenses in this area for high power broadcast and Mormon Mountain is the only available site for high power use. Official notes from the annual Mormon Mountain Communication Site Users Association (MMUA) meetings as far back as 2002 has documented that additional tower space is needed for high power broadcasters and wireless carriers. Additional tower space can be accommodated by either allowing taller towers or more towers at the current 200 feet above ground level (AGL) limit. The expansion of MMCS communications facilities beyond the current encumbered area into adjacent undisturbed land may be limited because of the presence of the Mexican spotted owl, a listed species under the Endangered Species Act. The current approved site plan limits tower height to 200 feet (AGL). In response to the need for additional tower space, MMUA submitted a proposal in 2002 to amend the site plan that would authorize taller towers. The process was never completed because of lack of Forest Service funding and the lack of a communications site proponent willing to fund the NEPA process. The need for additional tower space for high power broadcasters and wireless carriers is well documented.

2. There is a need to establish and monument a boundary for MMCS. MMCS is

located in mixed conifer forest type and within critical habitat for Mexican spotted owls, a species listed as threatened under the Endangered Species Act. There is a concern that communication site activities associated with construction and maintenance could adversely affect spotted owls. Expansion of the site for additional tower space into undisturbed areas to accommodate the needs of FCC licensed broadcasters and low power providers could further impact habitat.

3. There is a need to reduce the density of trees, reduce dead and down fuels, and

remove falling tree hazards from to protect this important communication facility from wildfire and falling trees. MMCS is located in mixed conifer forest type and the permitted facilities are at risk to wildfire because of a build-up of dead and down fuels and high densities of trees. Recent drought conditions have resulted in large tree mortality within MMCS. Currently there are numerous dead trees that are a potential threat to communications site facilities. The timber stand in and around the electronic site is comprised of a mix of mature ponderosa pine, aspen, and Douglas fir. There is also individual southwestern white pine, white fir, and rocky mountain juniper which also

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Environmental Assessment for Mormon Mountain Communications Site, Coconino NF 7

occur within the stand. Stand structure is an uneven age mix of all species arranged in dense clumps. Regeneration of all species is abundant throughout the stand.

4. There is a need to provide antennae positions for wireless providers at greater

heights in order to provide reliable wireless service to the FH-3 corridor and the Mormon Lake area. Currently wireless telephone service is unavailable or unreliable in the Mormon Lake community and on portions of the Forest Highway 3 (FH-3) corridor. Wireless carrier antennae positions on the existing towers at MMCS are not high enough to provide service to this area. Wireless antennae positions at MMCS are generally located below the high power broadcast antennae because broadcast is the senior and priority use. Low power users and wireless providers have had to locate on towers with high power broadcast. This situation creates technical and operational problems for the low power users. Broadcasters are reluctant to power down their equipment when low power users have maintenance needs and the high power broadcast can cause interference problems for the low power site users.

1.4 Proposed Action The actions proposed to meet the purpose and need consist of:

1. Approve standards to be incorporated into a new Communications Site Plan for MMCS that will allow for additional tower space by allowing new towers and existing and/or replacement towers heights to be increased to 280 feet AGL. The new site plan standards will also require that new towers be free standing type towers. Free standing towers encumber less land than guyed towers making for more efficient use of the area designated for communications purposes.

2. Establish and monument a boundary for the communication site as depicted in

Figure 2. This proposed site boundary would designate the area allocated by the Forest Service for communications site management. All future communications site activities and facilities will be contained within this area. By establishing the boundary of MMCS, Mexican spotted owl habitat will be protected from further development of MMCS. The boundary will be delineated by posts installed at visible intervals.

3. Authorize fuel treatments within the MMCS designated area by thinning and

burning to reduce fuels on MMCS site to protect the communications towers and buildings from wildfire. Within the defensible perimeter it is proposed to thin trees by removal of all trees less than 9” DBH (diameter breast height). The defensible perimeter consists of the area within the site boundary. The lower branches of leave trees would be pruned to reduce the threat of fire ladders. All slash would be piled and burned. It is also proposed to remove all live and dead trees which pose a falling hazard or future falling hazard to equipment buildings and towers. All slash and logs would be removed to an opening outside of the MMCS boundaries identified by the Forest Service where the logs will be decked for removal and the slash piled for later burning. An initial broadcast burn will be undertaken after fuel treatment. Once ground cover vegetation becomes reestablished, regular maintenance burning would be conducted to reduce future regeneration and maintain the fuel break around the electronics site. Follow up thinning may be needed in the future to maintain prescribed stand densities.

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8 Environmental Assessment for Mormon Mountain Communications Site, Coconino NF

Figure 2 – MMCS location and proposed boundary.

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Environmental Assessment for Mormon Mountain Communications Site, Coconino NF 9

4. Construct a new low power collocation wireless communications facility within the

boundaries of the MMCS. The facility will consist of a free standing lattice tower and an equipment building designed to house all tenants. The equipment building and tower will be authorized by a FS Communications Use Lease. The facilities authorized by the lease will be owned and managed by the lease holder (Figure 3). Figure 4 depicts the wireless telephone coverage area (propagation map) that will be provided by the proposed new tower.

Proposed Action Rationale:

The new site plan standards resulting from the proposed action would allow for additional high power broadcast tower space without expanding MMCS designated area.

Further development of MMCS by allowing taller towers is proposed because:

• The MMCS location provides needed TV and FM broadcast signal coverage for high power broadcast to the Flagstaff area from an existing site designated for high power use.

• The MMCS location provides the best radio frequency (RF) propagation for wireless service for the Mormon Lake and FH-3 corridor, an area where service is currently unreliable or unavailable.

By allowing taller towers, MMCS will be able to address future communications needs without expanding the MMCS boundary and further impacting MSO habitat.

The designated boundary for MMCS is proposed because:

• The proposed boundary establishes the designated MMCS area on the ground and defines an area allocated for communications purposes that will accommodate current needs and future anticipated growth. The proposed boundary will be included as part of the new site plan and will establish and limit the area designated for communications purposes to the existing foot print. Establishing a boundary protects Mexican spotted owl habitat from further impacts as a result of additional development of MMCS

The fuel treatment prescription is proposed because:

• Thinning trees and reducing dead and down fuels reduces wildfire hazards protecting the site from potential destruction of high value communications equipment.

• Eliminating falling tree hazards and reducing fuels at the communications site reduces the chance of interruption of important communications services.

• Periodic treatment and prescribed burning at the site will maintain the defensible space created by the initial fuel treatments.

The proposed location for the new low power facility has been chosen to:

• Provide wireless communications where service is not currently available and/or reliable.

• Use an existing designated communications site. The new facilities will enable access for the general public to wireless communication services, including the ability to reach emergency response agencies, while minimizing use of National Forest System lands.

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Figure 3 – Control Survey depicting existing and proposed facilities.

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Environmental Assessment for Mormon Mountain Communications Site, Coconino NF 11

Figure 4 – Propagation Map. Green area depicts proposed wireless telephone service from the new tower.

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Environmental Assessment for Mormon Mountain Communications Site, Coconino NF 12

The proposed facility responds to site management issues associated with high and low power site users located within the same facility. The proposed new tower and equipment structure will provide an opportunity to separate high and low power site users.

The Coconino National Forest will evaluate the environmental consequences of the proposed action and alternatives to the proposed action in an Environmental Assessment. It is important to note that no decision has been made, and the environmental analysis is not a decision document. If the analysis demonstrates there are no significant impacts, a decision will be issued through a Decision Notice.

1.5 Decision Framework Given the purpose and need, the deciding official reviews the proposed action and the other alternatives in order to make the following decisions:

The decision to be made is whether to implement the proposed action, an alternative to the proposed action, or whether further environmental documentation is needed.

1.6 Public Involvement and Scoping The proposal was listed in the Schedule of Proposed Actions from January 1, 2009 to present. The proposal was provided to the public, MMCS site users, and other agencies for comment by means of a scoping letter mailed or e-mailed to 182 addresses. The scoping letter offered a comment period from March 12, 2009 to April 10, 2009. By April 11, 39 responses were received.

1.7 Issues Identified from Scoping The following is Forest Service Direction for addressing Issues:

“Issues serve to highlight effects or unintended consequences that may occur from the proposed action and alternatives, giving opportunities during the analysis to reduce adverse effects and compare trade-offs for the decision maker and public to understand. Issues are best identified during scoping early in the process to help set the scope of the actions, alternatives, and effects to consider; but, due to the iterative nature of the NEPA process, additional issues may come to light at any time.

An issue should be phrased as a cause-effect statement relating actions under consideration. An issue statement should describe a specific action and the environmental effect(s) expected to result from that action. Cause-effect statements provide a way to understand and focus on the issues relevant to a particular decision”.

There is no set of standard issues applicable to every proposal, so it is important for the responsible official to consider a variety of laws, regulations, executive orders and input, with the help of the interdisciplinary team. The responsible official approves the issues to be analyzed in depth by the interdisciplinary team in the environmental analysis (FSM 1950.41). It is often helpful to organize and group similar issues by common resource,

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Environmental Assessment for Mormon Mountain Communications Site, Coconino NF 13

cause-effect relationships, same or common geographical area, or those linked to the same action. The Council for Environmental Quality (CEQ) NEPA regulations require this delineation in Sec. 1501.7, “…identify and eliminate from detailed study the issues which are not significant or which have been covered by prior environmental review (Sec. 1506.3)…”

Of the 38 responses received from the general public, 100% either were in favor or had no comments regarding the proposed changes to communications site management at MMCS. One commenter voiced support for improving communications available in the Mormon Lake area but requested that if the proposed facilities pose a threat to Bald Eagles restrictions be imposed on communication site operations. A Biological Evaluation for Forest Service Sensitive Species was completed as part of this NEPA process that addressed bald eagles. The evaluation concluded that the project will not impact bald eagles because the top of Mormon Mountain is not a place bald eagles typically rest, roost, or nest. Bald eagles prefer areas close to larger water bodies like Mormon Lake.

The U.S. Fish and Wildlife Service (USFWS) responded with a letter expressing concerns with the barbed wire fence that was included in the proposed action for scoping. They were concerned with the potential for foraging owls to collide with the new fence. They were also concerned with additional Federal Aviation Administration (FAA) lighting requirements that might result from taller towers. USFWS also suggested that construction activities at MMCS be restricted to the time period outside of Mexican spotted owl (MSO) breeding season (March 1 – August 31). The following adjustments to the proposed action were made in response to USFWS comments:

1. The barbed wire fence was removed from the proposed action. The MMCS boundary will be marked by posts at visible intervals.

2. The taller towers authorized as part of the proposed action will not require additional lighting. The one existing light on top of the tallest tower at MMCS will remain the only light on the site. New towers and extensions of existing towers will be limited to 280 feet AGL which will be lower than the tallest existing tower, which currently has a light on top. Therefore new and/or replacement towers will not require additional FAA lighting.

3. A construction timing restriction will be specified as mitigation and will be imposed as part of the new communications plan that prohibits construction during the MSO breeding and nesting season (March 1 – August 31).

Because the comments received from the pubic during scoping were either positive or neutral and the comments from USFWS were addressed by modifying the proposed action and specifying mitigation measures, it is concluded that there are no significant issues associated with the proposed action.

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14 Environmental Assessment for Mormon Mountain Communications Site, Coconino NF

Chapter 2 – Alternatives

This chapter describes and compares the alternatives considered for MMCS management. This section also presents the alternatives in comparative form, sharply defining the differences between each alternative and providing a clear basis for choice among options by the decision maker and the public. Some of the information used to compare the alternatives is based upon the design of the alternative and some of the information is based upon the environmental, social and economic effects of implementing each alternative.

Because there were no significant issues identified during the scoping process alternatives to the proposed action were not developed or analyzed in detail. During the process to develop the proposed action numerous potential alternatives were studied in concept and eventually dropped from further consideration because they did not meet the purpose and need of the project. The section below describes the two alternatives analyzed in detail and the alternatives considered but eliminated from detailed study. The No Action alternative is required under NEPA and is used to compare the impacts of the proposed action to the existing condition.

2.1 Alternatives

Alternative 1 – No Action Under the No Action alternative, current management plans would continue to guide management of the project area. No new communication towers would be implemented to accomplish project goals and no new fuel treatments would occur.

Alternative 2 – The Proposed Action The actions proposed to meet the purpose and need consist of:

1. Approving new tower height standards for incorporation into a new Communications Site Plan that will authorize new, existing, or replacement tower heights to be increased to 280 feet AGL. The new tower standards also require that new towers be free standing towers. Free standing towers encumber less land making for more efficient use of the area designated for communications purposes.

2. Survey and monument a boundary for the communication site. The site boundary will

establish the area allocated by the Forest Service for communications site management. All future communications site activities and facilities will be contained within this area protecting adjacent spotted owl habitat. (Figure 3)

3. Thin trees, remove hazard trees, and burn slash and down fuels on the 11.7 acre MMCS

to protect the communications towers and buildings from wildfire and falling trees.

4. Constructing a new low power wireless communications facility within the boundaries of the Mormon Mountain Communications site. The facility will consist of a free standing lattice tower and associated equipment buildings. The new facility will provide reliable

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Environmental Assessment for Mormon Mountain Communications Site, Coconino NF 15

wireless service for the Mormon Lake Community and the FH-3 corridor. See Figure 4 depicting wireless telephone signal propagation from the proposed new tower.

2.2 Alternatives Considered and Eliminated From Detailed Study

Alternative 3 – Private Land Alternatives on private land were investigated. Communications sites are usually located on mountaintops to provide higher elevations for antenna positions which enable radio transmissions to cover larger geographic areas. There is no private land located on the mountain tops and/or hills in this area. The private land in the Mormon Lake area is typically bottom land and meadows. In order to provide the same broadcast coverage as Mormon Mountain provides a tower on private land would need to be at least 1,500 feet tall which would be impractical and environmentally unacceptable. Therefore, alternatives on private land were dropped from further consideration.

Alternative 4 – Other Mountain Tops Other mountain tops and hills in the area were considered but dropped from detailed analysis because development of new communications sites in this area would be inconsistent with CNFLMP direction and would not provide coverage to the targeted area currently served by the existing MMCS facilities. Management direction in the CNFLMP for communications sites is to “minimize the number of electronic sites and utility corridors consistent with appropriate pubic services that can only be met on Forest lands and to administer special uses to best meet public needs”.

Alternative 5 – Expand the area of MMCS Allowing for expansion of communications facilities by increasing the area designated for MMCS was considered but dropped from detailed consideration because of the need to protect Mexican spotted owl habitat. In addition, it would not meet the purpose and need because a new tower less than 200 feet AGL would not provide reliable wireless service in the Mormon Lake and FH-3 corridor area.

2.3 Mitigation Measures Mitigation measures would be implemented to reduce or avoid potential impacts to resources that could result from construction of the proposed project. In general, the project, including all construction-related activities, is required to comply with federal, state, and local laws, guidelines, or standards specific to each resource (i.e. water quality, soils, cultural or biological resources, etc.) Lease holders would obtain any necessary project permits as required by these laws. The project is also required to comply with the Forest Plan Standards and Guidelines Best Management Practices.

All laws and existing guidance that the project must comply with are not summarized below, and in some instances the existing requirements may provide sufficient mitigation without the development of project-specific measures. The application of resource-specific mitigation

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16 Environmental Assessment for Mormon Mountain Communications Site, Coconino NF

measures at the proposed site is described in the analysis sections of Chapter 3, as appropriate. The mitigation measures will be incorporated into the new Communications Site Plan and will be required for all communications site operation and maintenance activities. The following mitigation measures will be included as part of the proposed action:

Soil and Water 1. Haul oils or chemicals off site to an approved site for disposal to address the prevention

of oil products from entering into groundwater or navigable water of the United States. Spills are not expected, but should they occur would likely be minimal and would be immediately addressed in accordance with state and federal standards. Any spills, exceeding standard levels, would warrant the notification of the appropriate agency.

2. If soil moisture will cause rutting by construction equipment (greater that 2 inches in depth for a length greater than 25 feet), movement of construction equipment will not be allowed on the right-of-way, access roads, or other areas for a period of 48 hours or as directed by the Forest Service.

3. Restrict construction movement outside the right-of-way to pre-designated access areas, existing roads, or as approved by the Forest Service.

4. Leave existing roads in a condition equal to or better than their condition prior to project construction.

5. Construct no new access roads on Forest Service land and restrict overland travel to only rubber-tired vehicles.

Forest Noxious Weed Management Practices 1. All operations associated with the communications site lease shall be consistent with the

Forest Plan by following the Best Management Practices identified in the Northern Arizona Weed Management Practices Guide. Integrated weed management "is a system for the planning and implementation of a program, using an interdisciplinary approach, to select a method for containing or controlling an undesirable plant species or group of species using all available methods," (Food, Agriculture, Conservation, and Trade Act of 1990).

2. Require weed prevention and control in operating and maintenance plans when

authorized activities present a high risk for weed infestation or the location of the activity is vulnerable to weed introduction or spread.

Visual Resources 1. New towers will be solid leg lattice or monopole towers painted dark grey to blend into

the background. All antennas will be mounted to the tower on the same style of mounts to maintain a consistent look for the tower. In addition to tower style and color, the height of new or replacement towers will be limited to 280 feet above ground level (AGL). This height restriction will avoid the need for FAA lighting requirements because of the existing lighted 285 foot AGL tower (Gannet).

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Environmental Assessment for Mormon Mountain Communications Site, Coconino NF 17

2. Equipment buildings will be constructed to maintain a low profile and be painted to match the surroundings (FS dark brown).

Wildlife – Threatened and Endangered Species 1. A construction timing restriction is in place and will be continued to protect Mexican

spotted owls. No construction activities or road maintenance activities are allowed from March 1 through August 30 to reduce noise and human activity during MSO breeding and nesting season.

2. The new site plan establishes a boundary for MMCS. All future communications site development and activities will be restricted to the area within the 11.7 acres site shown in Figure 2.

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18 Environmental Assessment for Mormon Mountain Communications Site, Coconino NF

Chapter 3 – Affected Environment and Environmental Consequences

This section summarizes the physical, biological, social and economic environments of the affected project area and the potential changes to those environments due to implementation of the alternatives. It also presents the scientific and analytical basis for the comparison of alternatives presented in the chart above.

This chapter summarizes the existing environmental conditions found within the affected project area and potential changes that may occur from implementing the Proposed Action. Development occurring on non-Forest Service lands and, therefore, not within the scope of the Proposed Action and the Forest Service decision are discussed in the cumulative impacts sections for each resource. Resources associated with the natural, human, and cultural environment were studied.

Environmental conditions were assessed for the following resource categories:

• Earth and Water Resources • Biological Resources • Land Use and Recreation • Socioeconomic and Environmental Justice • Visual Resources • Cultural Resources • Air Quality • Noise

The affected environment for the proposed project is referred to as the “study area” unless a resource is known to be affected beyond the limits of the study area. The study area includes all areas within a mile radius of the proposed wireless site.

3.1 Past, Present, and Reasonably Foreseeable Future Activities

For the cumulative effects analysis the impacts of the Proposed Action, when added to other past, present, and reasonably foreseeable future actions, were considered within the study area boundary. Depending on the resource, activities considered in this analysis may vary. The area for the cumulative effects analysis is the 11.7-acre MMCS, within which project activities will be contained. The length of time considered for cumulative effects is 20 years, which corresponds to the period of time that the lease will be issued. When the proposed lease expires, continued operation of the facilities will be subject to new environmental analysis and approval of a new lease.

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Environmental Assessment for Mormon Mountain Communications Site, Coconino NF 19

3.2 Earth and Water Resources

Affected Environment

General Geology The project area occurs at an approximate elevation of 8,456 feet above mean sea level.

Surface geology of the project site is Quaternary volcanic rock that is rhyolitic to andesitic in composition (Moore et al. 1960).

Soils Soils are classified as Sponseller-Ess-Gordo Association, which is characterized as moderately deep and deep, medium and moderately fine-textured, moderately sloping to steep mountain soils (Hendricks 1985). Rock content of the soil is more than 35%.

Water There are no naturally occurring perennial surface water resources in the study area. MMCS is located at the top of Mormon Mountain consequently all surface water drains from the site. There is a livestock tank located approximately 1000 feet south of MMCS.

Environmental Consequences – Earth and Water Resources

Alternative 1 – No Action Under the No Action Alternative, the current soil and water conditions associated with the project area would remain unchanged, and no impacts would occur. No impacts to water resources are anticipated from the proposed project because there are no naturally occurring perennial surface water resources in the study area.

Alternative 2 – Proposed Action The effects of the proposed activities would be localized, and there would be minimal effects to soil and water resources. Impacts to soil resources from the Proposed Action are expected to be minimal. Soil disturbance will be kept to a minimum by using existing access roads. During construction and maintenance, soil erosion would be minimized by implementing standard construction erosion-control best management practices and mitigation measures

Cumulative Effects – Earth and Water Resources

Alternative 1 – No Action Implementation of Alternative 1, along with past, present, and reasonably foreseeable actions, would have no cumulative effects to soil and water resources.

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20 Environmental Assessment for Mormon Mountain Communications Site, Coconino NF

Alternative 2 – Proposed Action Implementation of best management practices and other construction planning activities will effectively reduce the potential negative effects from construction of the proposed action. There are no other earth-moving related developments being planned in the project vicinity, in the foreseeable future that would result in cumulative effects to soil and water resources. Therefore, implementation of Alternative 2, along with past, present, and reasonably foreseeable actions, would have minimal cumulative effects to soil and water resources.

3.3 Biological Resources This section provides a general description of the existing environment with respect to vegetation; riparian habitat; invasive plant species; and threatened, endangered, and sensitive species for the Peaks Ranger District on the CNF.

Threatened and Endangered Species (T&E)

Regulatory Requirements - T & E Species The Endangered Species Act (ESA, PL 93-205), Forest Service Manuals (FSM) 2670.11, 2670.21 and 2670.31 directions, the Coconino National Forest Plan standards (replacement page 23, 64) all require that National Forest System lands are not only managed for endangered, threatened and proposed (TEP) species, but also to recover TEP species. The ESA states that all Federal departments and agencies shall seek to conserve TEP species. FSM 2670 directs Forests to manage National Forest System habitats to achieve recovery of TEP species and to avoid the need to implement special protection measures under the ESA.

Affected Environment – T & E Species The USFWS list of endangered, threatened, and candidate species for Coconino County was reviewed by a qualified biologist (Ron van Ommeren, EcoPlan Associates, Inc.) to determine which species may occur in the project area (USFWS 2009b). On April 21, 2009, the Arizona Game and Fish Department On-line Environmental Review Tool was accessed to obtain updated records of special status species in the project vicinity (receipt attached). The CNF Mormon Lake Ranger District was contacted to obtain more specific information regarding federally listed species with records in the project vicinity. A project site visit was completed on April 23, 2009, to characterize the area and to assess the potential occurrence of habitat for federally listed and candidate species. The CNF conducted MSO surveys at the MMCS in 2008. The following species is analyzed in detail in the BE, based on the aforementioned sources.

Common Name Scientific Name Status Mexican spotted owl Strix occidentalis lucida USFWS threatened The potential occurrence of federally listed or candidate species is limited to the MSO. The project area is located within designated critical habitat for this species and occurs in the direct vicinity of five Protected Activity Centers (PACs) designated by the CNF. Surveys conducted for MSOs at the MMCS in 2008 found a new pair of owls for which a new PAC (Mormon Mountain) will be designated. This PAC will completely surround but exclude the MMCS. A detailed

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Environmental Assessment for Mormon Mountain Communications Site, Coconino NF 21

discussion of the status of the species in the project area and potential effects of proposed project is contained in the BA&E for listed species found in the project record.

Environmental Consequences – T & E Species

Alternative 1 (No Action): Under the No Action there are no activities and therefore no impacts to any T & E species.

Alternative 2 – The Proposed Action Short-term Effects

The construction of a new cell tower and equipment building at the MMCS and associated vegetation management activities will not affect MSO breeding activities but may affect MSOs outside the breeding season. Construction activities will take place after August 31 and will be completed prior to March 1 to avoid impacts to MSO nesting activities in nearby PACs. At the time when construction starts, MSO young are expected to be nearly or fully independent from adults. Noise and human presence/activity will likely result in avoidance of the project area and its immediate vicinity during construction and/or some localized and temporary displacement of young or adults, but is not expected to result in any mortality.

Long-term Effects

Direct/Indirect Effects - Construction and maintenance of the new cell tower and the thinning of vegetation within the MMCS is expected to have limited long-term effects on MSOs or their habitat. Though a number of bird species are adversely affected by collisions with communications towers, these are primarily migratory passerine birds (Kerlinger 2000). MSOs are resident/non-migratory, and the existing monitoring data show no evidence that the existing facilities have had a negative effect on MSOs. Communications towers and associated facilities have been present on Mormon Mountain since 1969, and the PACs surrounding the MMCS have been more or less continuously occupied since monitoring started (generally in the late 1980s) and all have fledged young.

Though there has been substantial variation in occupancy rates and reproductive success between the PACs, these differences are not readily attributable to the presence of the communications facilities and show no clear trend over the monitoring history. It is possible that young MSOs dispersing from these PACs could collide with the tower or building. However, there is little evidence of accidental collisions involving MSOs, with the exception of vehicle collisions (USFWS 1995) or collisions with fences. Vegetation management, particularly the removal of larger trees within the MMCS to reduce fall hazard, will reduce overall canopy cover and may increase habitat suitability for MSO predators such as the great horned owl (Bubo virginianus) or the Northern goshawk (Accipiter gentilis) and MSO prey species such as small mammals. This effect is likely to be small, considering the partially disturbed condition of the MMCS at this time.

Effects to MSO Habitat and Designated Critical Habitat - Vegetation management within the MMCS will affect some primary constituent elements within designated critical habitat for MSOs. Primary constituent elements present relate to forest structure and primarily include a range of tree species in an uneven-aged stand structure and a substantial number of trees and

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22 Environmental Assessment for Mormon Mountain Communications Site, Coconino NF

snags with a large trunk diameter. The stand in and surrounding the MMCS is estimated to support a basal area of approximately 150 square feet per acre. The proposed action will adversely affect primary constituent elements for MSOs related to forest structure. Removal of hazard trees from the MMCS may result in the elimination of up to 59 live trees and 15 snags greater than 24-inch DBH and the elimination of 87 live trees and 17 snags between 18 and 24 inches DBH. It is unlikely that all of these trees and snags present a hazard to the site and will be removed, though it is not known at this time which trees and snags will be removed or how many. Removal of hazard trees from the MMCS will adversely affect primary constituent elements for MSOs by (1) reducing the number of larger trees, (2) reducing canopy closure, and (3) reducing the number of large dead snags within the MMCS. This will eliminate potential natural roost and perch sites for MSOs in undeveloped portions of the MMCS. Opening up of the habitat may also improve conditions for MSO predators such as the great horned owl. Therefore, the proposed action is likely to adversely affect primary constituent elements for MSOs within the 11.7-acre MMCS.

Cumulative Effects – T & E Species

Past construction and ongoing maintenance of the seven currently existing communications towers and associated facilities at the MMCS has reduced potential foraging and natural roosting and perching habitat over the affected portions of the project site but is not known to have affected occupancy and reproductive success of nearby PACs or to have reduced available nesting habitat in the area. Construction of the new cell tower and equipment building will reduce potential foraging habitat and improve habitat for predators, while removal of hazard trees may improve habitat conditions for prey species over the remainder of the 11.7-acre project site. There are no future federal or non-federal projects that are reasonably certain to occur that would potentially affect the MSOs occupying the nearby PACs or foraging in the area.

Forest Service Sensitive Species

Regulatory Requirements Forest Service Manual 2621.2 directs managers to display findings under the various management alternatives considered for individual projects. This assessment is based on the current geographic range of sensitive species on the Coconino National Forest and the area affected by the project. This assessment considers, as appropriate for the species and area, factors that may affect the current trend for the species’ population. Sensitive species are defined as "those plant and animal species identified by a Regional Forester for which population viability is a concern, as evidenced by:

a) Significant current or predicted downward trends in population numbers or density, or b) Significant current or predicted downward trends in habitat capability that would reduce a

species' existing distribution (FSM 2670.5(19))".

Affected Environment – Sensitive Species On April 21, 2009, the Arizona Game and Fish Department (AGFD) On-line Environmental Review Tool was accessed to obtain updated records of special status species in the project

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Environmental Assessment for Mormon Mountain Communications Site, Coconino NF 23

vicinity. The CNF Mormon Lake Ranger District provided a list of special status species, which included Forest Service sensitive species, and was contacted at various times in April and May 2009 to obtain more specific information regarding special status species with records in the project vicinity. A field investigation was completed on April 23, 2009, to characterize the area and to assess the potential occurrence of habitat for special status species. No species-specific surveys were completed as part of this evaluation. The species listed in Table 2 are analyzed in detail in the BE completed by EcoPlan Associates, Inc. based on the aforementioned sources.

Table 2. Forest Service sensitive species analyzed. Common Name Scientific Name Merriam’s shrew Sorex merriami leucogenys Long-tailed vole Microtus longicaudus Allen’s big-eared bat Idionycteris phyllotis Pale Townsend’s big-eared bat

Corynorhinus townsendii pallescens

Northern goshawk Accipiter gentilis American peregrine falcon Falco peregrinus anatum Bald eagle Haliaeetus leucocephalus Clark’s grebe Aechmophorus clarkii Northern leopard frog Rana pipiens Arizona sneezeweed Helenium arizonicum Rusby’s milk vetch Astragalus rusbyi

Alternative 1 (No Action)

The no action alternative will not affect overall habitat or population trends for Sensitive Species on the CNF.

Alternative 2 (The Proposed Action)

The proposed action would not affect the overall habitat or population trends for Sensitive Species on the CNF. Information supporting this conclusion is found in the Biological Evaluation for Forest Service Sensitive Species completed by EcoPlan Associates Inc. dated June 3, 2009 and can be found in the project record.

Cumulative Effects

The area for the cumulative effects analysis is the 11.7-acre MMCS and the length of time considered for such effects is 20 years. Development of the existing communications site has resulted in some permanent loss of habitat. There are no future projects that are reasonably certain to occur that would additionally affect any Forest Service sensitive species occupying the area.

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24 Environmental Assessment for Mormon Mountain Communications Site, Coconino NF

Management Indicator Species (MIS)

Regulatory Requirements The Coconino National Forest’s (CNF) Land Management Plan (LMP) was prepared under planning regulations issued in 1982. The Forest Service is required to address MIS in compliance with various regulations and agency policy (e.g. 36 CFR 219, Forest Service Manual (FSM) 2621, FSM 1920), which are, themselves, tiered to the Forest and Rangeland Renewable Resources Planning Act of 1974 (RPA), as amended by the National Forest Management Act of 1976 (NFMA). FSM 2621 provides specific direction for management of MIS species. Forest Service Policy and direction regarding species selection, habitat analysis, monitoring and evaluation, and other habitat and planning evaluation considerations regarding MIS at the Forest Plan and project level are given in FSM 2620 which tiers to the CFR 219.9. FSM 2630 provides guidance on improving MIS habitat, conducting habitat examinations, and conducting project level evaluations of MIS and their habitat within the project area.

Affected Environment - MIS The habitats present within the project area are mixed conifer and aspen. No other habitats are present within the project area. Information on indicator species identification, habitat, and population trends is summarized from the CNF 2002 MIS analysis (CNF 2002). Table 3 summarizes acres of habitat and current habitat availability trends for MIS in the project area. The analysis area consists of the 11.7-acre MMCS.

Table 3. Summary of MIS habitat in the project area. Indicator or Key Habitat Condition

Trend (acres) Species Indicator or Key Habitat Condition

Upward Downward Stable

Total Acres

Elk Early seral ponderosa pine, mixed conifer, and spruce-fir

X 11.7

Mule deer Early seral aspen and pinyon juniper

X 11.7

Red squirrel Late seral mixed conifer and spruce-fir

X 11.7

Mexican spotted owl Late seral mixed conifer and spruce-fir

X 11.7

Hairy woodpecker Snag component of ponderosa pine, mixed conifer, and spruce-fir

X 11.7

Red-naped sapsucker Late seral and snag component of aspen

X 11.7

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Environmental Consequences - MIS Alternative 1 (No Action)

Under the No Action alternative, habitat conditions at the MMCS would remain unchanged over the short-term and therefore there would be no impacts to MIS.

Alternative 2 – The Proposed Action Effects of the Proposed Action on MIS are summarized in Table 4; details are located in the wildlife specialist report in the project record.

Table 4. Anticipated effects to MIS under the proposed action.

Are Species Impacted?

Are Impacts

Significant? Species Indicator of:

Likely Not Likely Yes No

Elk (Cervus elaphus) Early seral m/c X X Mule deer (Odocoileus hemionus) Early seral

aspen X X

Red squirrel (Tamiasciurus hudsonicus) Late seral m/c X X Mexican spotted owl (Strix occidentalis lucida)

Late seral m/c X X

Hairy woodpecker (Picoides villosus) Snags m/c X X Red-naped sapsucker (Sphyrapicus nachalis)

Snags aspen X X

Cumulative Effects - MIS The area for the cumulative effects analysis is the 11.7-acre MMCS and the length of time considered for such effects is 20 years. Development of the existing communications site has resulted in some permanent loss of habitat. There are no future projects that are reasonably certain to occur that would additionally affect any MIS species occupying the area.

Migratory Birds President Clinton signed Executive Order 13186 on January 10, 2001, placing emphasis on conservation of migratory birds. This order requires that an analysis be made of the effects of Forest Service actions on Species of Concern listed by Partners in Flight (PIF), the effects on Important Bird Areas (IBA’s) identified by Partners in Flight (Latta, et al. 1999), and the effects to important over wintering areas.

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26 Environmental Assessment for Mormon Mountain Communications Site, Coconino NF

Affected Environment – Migratory Birds Arizona State Partners in Flight and the USFWS list priority species of concern by vegetation type. Mixed conifer and aspen vegetation types occur in the project area. All species of concern for these vegetation types were reviewed.

The MMCS is within the boundaries of the Anderson Mesa Important Bird Area (IBA). This IBA is one of two major waterfowl use areas in Arizona during migration, particularly for dabbling ducks during spring migration. In the early 1990s, over 2000 waterfowl were documented using this area during spring migration. This IBA has been affected by recent drought but remains a significant migration stopover site for waterfowl, water birds, and wading birds during wet winters. Livestock grazing has been identified as a secondary threat to this IBA (National Audubon Society 2009).

Important overwintering areas in the project vicinity are large wetlands and water bodies such as Mormon Lake, Upper and Lower Lake Mary, and Marshall Lake. The importance of the MMCS as an overwintering area is very limited due to the lack of perennial surface water and to its high elevation.

Environmental Consequences – Migratory Birds Alternative 1 (No Action)

Under the No Action alternative, habitat conditions at the MMCS would remain unchanged over the short-term.

Alternative 2 (Proposed Action)

Effects to the northern goshawk, the Mexican spotted owl, and the peregrine falcon are discussed in the Threatened and Endangered Species or Sensitive Species sections of the Environmental Assessment. The proposed action would result in the permanent loss of ¼ acre of forested habitat that may be suitable for foraging and/or nesting by the golden eagle, the flammulated owl, and the Cordilleran flycatcher, and that may be used as foraging habitat by the red-faced warbler. Removal of large trees and snags within the 11.7-acre MMCS site would eliminate potential nest sites for the golden eagle, the flammulated owl, and Cordilleran flycatcher, and alter foraging habitat for these species as well as the red-faced warbler.

Construction and operation of the new cell tower would not substantially increase the potential for collisions and associated mortality in migratory birds. Smaller passerine neotropical migrant birds are more likely to be impacted by communications towers because they migrate at night, at higher elevations, and can become disoriented by or attracted to warning lights (Kerlinger 2000, Avatar LLC 2004, Manville 2005). Towers most prone to collisions are tall (particularly those in excess of 1,000 feet high), illuminated by solid or pulsating incandescent red lights, guyed, near wetlands, and in major songbird migration corridors (Manville 2005). Design and construction of new facilities at the MMCS would conform to USFWS interim guidelines for siting and construction of communications facilities (USFWS 2000, USFWS 2009) in the following respects: (1) the proposed new cell tower and equipment building would be collocated with seven existing cell towers and associated facilities, (2) there would be no additional lighting and all new and replacement towers would not exceed 280 feet high, (3) new or replacement towers would be freestanding and any existing guyed towers that need replacement would be replaced by

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Environmental Assessment for Mormon Mountain Communications Site, Coconino NF 27

freestanding towers, (4) the new communications site plan will stipulate that all facilities will be designed and constructed to accommodate collocation of compatible communications site users, (5) no security lighting would be used, and (6) researchers from the Communication Tower Working Group would be authorized to access the site to evaluate bird use and mortality.

Nevertheless, the potential remains for some mortality of migratory songbirds during spring and fall migration and construction and operation of the new cell tower would result in an incremental increase in this risk at the MMCS. Data collected from existing cell towers in northern Arizona suggest that this impact would be limited. A three-year study conducted on six cellular communication tower facilities along the Interstate 17 corridor on the Prescott and Coconino national forests recorded few bird strikes (Derby 2006). In spring 2004, a single carcass of a chipping sparrow (Spizella pallida) was recovered, though it is not thought to have collided with the tower. In 2005, two bird carcasses (one yellow-headed blackbird (Xanthocephalus xanthocephalus) and one MacGillivray’s warbler (Oporornis agilis) were recovered during the fall survey period and were thought to have resulted from collisions with the towers. No bird carcasses were recovered in 2006 (Derby 2006). The towers in this study were shorter in height (150–195 feet versus a proposed 280-foot tower at the MMCS), though they were similar to the proposed new tower at the MMCS in the fact that they are unlit and unguyed. Based on these considerations and the existing data, the project may result in the death (take) of a few migratory birds but will not affect range-wide population levels of any migratory bird species.

The proposed action would not adversely affect the Anderson Mesa IBA. Though the MMCS is within the boundaries of this IBA, project activities should not affect it because the nearest water body (Mormon Lake) is 2 miles southeast and 1,300 feet down slope in elevation. The primary birds for which this IBA was established (waterfowl, water birds, and wading birds) are not expected to occur at the MMCS. There is some potential for collisions with the proposed new cell tower, though this risk is relatively low because waterfowl and water birds generally migrate at lower elevations than passerines that migrate at night.

Because the MMCS is not considered an important overwintering area, the proposed action would not affect important overwintering areas.

Cumulative Effects – Migratory Birds The area for the cumulative effects analysis is the 11.7-acre MMCS and the length of time considered for such effects is 20 years. Development of the existing communications site has resulted in some permanent loss of habitat for migratory birds within the 11.7-acre MMCS. It has also introduced the potential for bird collisions with towers during spring and fall migration. Past and future livestock grazing on the Tinny Springs Allotment may have some additional cumulative effects, though grazing is on a rest-rotation system and is monitored for resource utilization, including in riparian areas. There are no other future projects that are reasonably certain to occur that would additionally affect habitat for migratory birds.

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28 Environmental Assessment for Mormon Mountain Communications Site, Coconino NF

Vegetation

Affected Environment - Vegetation Vegetation type in the project area is described as mixed conifer consisting of ponderosa pine, Douglas fir, white fir, and aspen. The dominant shrub is snowberry, with some gooseberry throughout the site.

Vegetation in the project area is Rocky Mountain (Petran) subalpine conifer forest (Pase and Brown 1994). The forest stand in and around the project site is composed of a mix of mature ponderosa pine (Pinus ponderosa), quaking aspen (Populus tremuloides), and Douglas-fir (Pseudotsuga menziesii). Individual Southwestern white pines (Pinus strobiformis), white firs (Abies concolor), and rocky mountain junipers (Juniperus scopulorum) also occur within the stand. Stand structure is an uneven-aged mix of all species arranged in dense clumps (more than 150 square feet per acre in basal area) and scattered individuals with several small openings occurring in the stand. Regeneration of all species is abundant in the stand.

Environmental Consequences - Vegetation

Alternative 1 – No Action Under the No Action alternative, vegetation conditions at the MMCS would remain unchanged over the short-term, and there would be no removal of hazard trees and snags or thinning. Implementation of the No-Action Alternative will result in the project area remaining in its current condition and will result in no impacts to vegetation.

Alternative 2 – The Proposed Action As a result of the proximity and ease of access from FH-3 and existing Forest System roads, additional disturbance to plants and wildlife is anticipated to be minimal. The use of existing access, combined with mitigation measures, will minimize clearing and loss of vegetation at the proposed location. The proposed action will have a positive impact on forest health. Thinning of the Forest within MMCS will result in a general improvement in forest health and a reduced risk for catastrophic wildfire in the immediate area of MMCS.

Live trees and snags that are a potential falling hazard to the buildings, towers, and guy wires will be removed within the communications site. Impacts to vegetation from this activity will be limited to the area within the 11 acre site. Overall effects to the vegetation in the area will be minimal in the context of the acreage impacted to the acreage of MA 4.

An initial broadcast burn will be done, which may cause acceptable tree mortality within the defensible perimeter, particularly with aspen. Once ground cover vegetation becomes reestablished, regular maintenance burning would be conducted to reduce future regeneration and maintain reduced fire hazard around the electronics site. Follow up thinning may be needed in the future to remove unwanted regeneration. An inventory of larger trees that occur within MMCS was completed during field evaluation. Table 5 lists the number of larger trees and snags by species and size class that may be subject to removal.

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Environmental Assessment for Mormon Mountain Communications Site, Coconino NF 29

Table 5. Inventory of larger trees and snags within the MMCS site boundaries. Species/Type Size Class (DBH) Total Number Density (No./Acre)

18–24 inches 87 7.4 Live trees >24 inches 59 5.0

18–24 inches 15 1.3 Snags >24 inches 17 1.5

Live trees by species Ponderosa pine 33 2.8 Douglas-fir 40 3.4 White fir 11 0.9 Aspen 1 0.09 Gambel oak

18–24 inches

2 0.2 Ponderosa pine 34 2.9 Douglas-fir 22 1.9

White fir

>24 inches

3 0.3

Cumulative Effects - Vegetation

Implementation of Alternative 1 or Alternative 2, along with past, present, and reasonably foreseeable actions, would have no cumulative effects to vegetation. The small size of the project as compared to the area represented by MA 4 when considered with past, present, and foreseeable actions will not result in cumulative effects.

Riparian Habitat The project area represents a mountain top in the mixed conifer vegetation type, with no discernible drainages. There are no aquatic, wetland, or riparian area on or near the site. Mormon Mountain Tank, approximately ⅛ mile south of the MMCS and directly south of FR648, is a depressional feature that appears to hold surface water only on an ephemeral basis.

Invasive Plants No invasive plants were identified within the project area.

3.4 Land Use This section provides a general description of the existing environment with respect to Land use and recreation for the Mormon Lake area on the Mormon Lake ranger District of the CNF. Information on biological resources was obtained from Coconino County Recorders Office, CNF special use files, and FS staff observations.

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30 Environmental Assessment for Mormon Mountain Communications Site, Coconino NF

Affected Environment – Land Use

Land Jurisdiction and Ownership The study area contains land under the jurisdiction of the United States Department of Agriculture, Forest Service, Coconino National Forest, Mormon Lake Ranger District. There are no land exchanges or other forms of major land ownership adjustment planned by the FS in this area.

Residences, Businesses, and Churches The study area (MMCS) is located on National Forest System lands with a consistent land ownership pattern. Very little private land exists in this area. The closest private land is located at the base of the mountain approximately 2 miles to the southeast. Recreation residences authorized under special use permit from the Forest Service are located at the base of the mountain approximately 1 ½ mile to the west at Dairy Springs and Double Springs. The closest large block of private landowners to MMCS is located over 5 miles to the southeast at the Mormon Lake town site. The nearest businesses are at similar locations, Mormon Lake Lodge is located approximately 5 miles to the southeast. Mormon Lake Lodge offers cabin rentals, general store, bar and restaurant, snowmobile rentals, horse rentals and hosts large events. Montezuma Lodge is located on Forest Service land approximately 1 ½ miles to the east. Montezuma Lodge has rental cabins operated under special use permit from the Forest Service. The nearest church is over twenty five miles away in Flagstaff. There is a church affiliated youth camp (St Josephs) located at the base of the mountain near Double Springs Campground.

Utilities Arizona Public Service Company provides electrical power to the communications site via an underground line feeding off the Flagstaff to Happy Jack 12k line. TDS Telecom provides land line phone service to the residences in the Mormon Lake area.

Transportation Forest Highway 3 is the main access road to the general area. Numerous Forest System roads provide access to Mormon Mountain including FR 90, FR 132A, FR 132, FR 240, and FR 648. Principal access to the site is from Forest Highway 3 to Forest Road 90, Forest Road 132A, and Forest Road 648.

The top of the mountain was closed to motorized vehicles in the mid-1990’s to protect wild turkey habitat and breeding and to restrict public access to MMCS. A gate at the mountain summit on FR 648, and parking area were installed. The parking area now serves as a trail head for non motorized access to the top of the mountain. There is a hiking trail that provides pedestrian and equestrian access to the top of the mountain. The trail begins at Dairy Springs Campground and reaches the top of the mountain approximately ½ mile southwest of the communications site.

Recreation The adjacent Forest Service land provides opportunities for all-terrain vehicle use, camping, picnicking, hiking, horseback riding, mountain biking, hunting, snowmobiling, cross country

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Environmental Assessment for Mormon Mountain Communications Site, Coconino NF 31

skiing, and scenery viewing. Current recreation use in this area is heavy especially on holiday weekends. A portion of the Arizona Trail is located along the east flank of Mormon Mountain, approximately ¼ mile east of MMCS. Mormon Lake Lodge attracts large numbers of visitors during the summer for events. The Lodge has a roping arena and holds several major roping events on holidays including Memorial Day, Fourth of July, and Labor Day. The Mormon Lake area has cross country skiing trails and snowmobile trails maintained and operated under FS special use permits and are popular when snow cover is adequate. The area and the mountain receive heavy use from big game hunters from late August to early December. Large numbers of elk and deer hunters camp and hunt in this area each fall.

The Mormon Lake area is also the site of three Forest Service Recreation Residences tracts that have been in existence since the 1920s. The tracts include Double Springs, Dairy Springs, Rock Ledge, and Tempe Camp with a total of 90 cabins. Current FS plans are for continuation of these special use permits.

According to the Forest Land Management Plan, the proposed action is located within Management Area (MA) 4. MA 4 contains 32,677 acres and is made up of ponderosa pine and mixed conifer on slopes greater than 40%. Recreation and wildlife are the major uses of the mixed conifer.

Range Resources Grazing allotments are administered by the CNF, and were identified during land use studies. The proposed wireless communications site is located within the Mud/Tinny Grazing Allotment. The project area represents undeveloped open space. There is evidence of livestock grazing and past logging. The proposed action will have no impact on grazing operations and will not reduce livestock numbers on the grazing allotment.

Future Land Use MMCS is located in and surrounded by the Coconino National Forest. Known or planned future projects in the area include fuel reduction projects (Mormon Basin), grazing, and continued management for dispersed recreation. MMCS has been in existence since 1969 when a television broadcast facility was constructed. The site is currently occupied by seven towers and a NRCS Snowtel station.

Agency Plans According to the CNF Land and Resource Management Plan (1987), the study area is in the Management Area (MA) 4. MA 4 contains 32,677 acres and is made up of ponderosa pine and mixed conifer on slopes greater than 40 %. Recreation and wildlife are the major uses of the mixed conifer. The woody composition of the mixed conifer consists of ponderosa pine, Douglas fir, white fir, and aspen in a wide variety of mixtures. The plan emphasizes a combination of multiple uses including timber and firewood production, wildlife habitat, livestock grazing, high quality water, and dispersed recreation.

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32 Environmental Assessment for Mormon Mountain Communications Site, Coconino NF

Environmental Consequences – Land Use

Alternative 1 – No Action No direct impacts on existing or planned land used, or recreation opportunities, will result through implementation of the No Action Alternative.

Alternative 2 – Proposed Action Impacts to land uses and recreation resources under this alternative are anticipated to be minimal. Existing access roads will be used at MMCS during project new construction and operational activities. No new access roads will be developed and existing roads will not be upgraded beyond the current Forest Service designation nor impeded by the Proposed Action. The proposed action does not represent any substantial change in the existing condition of recreation resources and activities.

No future land use impacts would result based on known future plans

Cumulative Effects – Land Uses

Alternative 1 – No Action Implementation of Alternative 1, along with past, present, and reasonably foreseeable actions, would have no cumulative effects to land use and recreation resources.

Alternative 2 – Proposed Action Implementation of Alternative 2, along with past, present, and reasonably foreseeable actions, would have no cumulative effects to land use and recreation resources.

3.5 Socioeconomics This section describes the demographic and economic characteristics found in the study area, potential changes that could result from the proposed project, and if the Proposed Action would potentially affect any low-income or minority populations, or American Indian tribes.

Affected Environment – Socioeconomics Local economic and employment opportunities are primarily found in Flagstaff, located approximately 25 miles north. The primary economic activities of Flagstaff are government, education, transportation, cultural, and tourism. The population of Flagstaff in 2005 was 57,391. Mormon Lake Lodge located approximately 5 miles southeast of the site is the major employer of the immediate area providing lodging, a restaurant, horseback riding, snowmobile rentals, cross country skiing and large recreation events such as roping events and motorcycle rallies.

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Environmental Consequences - Socioeconomics

Alternative 1 – No Action Wireless personal communication services southeast of Flagstaff along the FH-3 corridor are not currently available and/or reliable. Implementing the No Action Alternative will result in continued poor wireless communication services in the Mormon Lake area and FH-3 corridor and will limit opportunities for additional TV and FM broadcast stations.

Alternative 2 – Proposed Action Implementing the Proposed Action will improve the wireless personal communication services east of Flagstaff along the FH-3 corridor and Mormon Lake Town area. Communications with emergency services will be enhanced. The Proposed Action will also provide additional opportunities for new TV and Radio stations to locate at MMCS which will offer the residents of Northern Arizona greater choices for FM radio and TV programming. The Proposed Action responds to the goals and objectives outlined in the proposed MMCS Site Plan, and helps move the site towards desired conditions.

Part of the proposed action is for an unmanned telecommunication tower site and therefore the “probable effects on the population in the area” long-term, would be negligible to non-existent. There may be short-term, negligible benefits to the local and regional economy resulting from construction-related expenditures and employment. Local businesses would not suffer any appreciable adverse short or long-term economic impacts from any of the alternatives, and no businesses would be closed or eliminated as a result of implementation of the proposed action. The impact to the local population and local economy would be short-term and positive. A longer tem positive impact to the local economy would be reliable and consistent wireless internet service to the residents of the resident of Mormon Lake and to Mormon Lake Lodge, the major employer of the area. Reliable internet service would expand opportunities for economic activities in this rural area.

Cumulative Effects - Socioeconomics

Alternative 1 – No Action Under the No Action there are no activities and therefore no impacts and no cumulative effects.

Alternative 2 – Proposed Action Implementation of the Proposed Action will result in an increase in wireless personal communication services, an increase in tower space available for FM and TV broadcast, increased safety, and quicker emergency response times. The proposed site is designed to accommodate high power FM and TV broadcasters and all of the licensed wireless carriers in the area as well as future technologies that require vertical real estate. When considered with other past, present, and foreseeable projects in this area, there are no other projects that will have a similar effect and therefore no cumulative effects associated with the proposed action

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34 Environmental Assessment for Mormon Mountain Communications Site, Coconino NF

3.6 Environmental Justice Pursuant to Executive Order 12898 on Environmental Justice, Federal agencies are to make the achievement of environmental justice part of their mission by identifying and addressing, as appropriate, disproportionately high and adverse human health or environmental effects of their programs, policies, and activities on minority populations, low-income populations, and Indian tribes and allowing all portions of the population a meaningful opportunity to participate in the development of, compliance with, and enforcement of Federal law, regulations, and policies affecting human health or the environment regardless of race, color, national origin, or income.

The proposed alternatives do not result in disproportionate impacts to low-income populations, nor do they impact minority populations. The Flagstaff area, including its low income and minority populations is strongly tied to the tourism industry, with cellular companies and TV and radio broadcast having a very small percentage of the overall economy.

3.7 Visual Quality

Affected Environment – Visual Quality Visual Management emphasis for MA 4 in the CNFLMP is to “Manage for a Visual Quality Objective (VQO) of Retention and Partial Retention in designated foreground areas, as specified in MA 4 and all VQOs in middle ground and background. The FLMP visual quality objective maps indicate that Mormon Mountain is seen as middle-ground as viewed from Forest Highway 3. FH-3 provides views of Mormon Mountain looking north while approaching the Mormon Lake area from the south, looking west from the Mormon Lake overlook and looking south from the Lake Mary area. The Plan VQO map also shows Mormon Mountain is seen as middle-ground from Forest Road 90 which, beginning at FH-3 on the northeast side of Mormon Lake, loops around the west side of the lake near the east flank of the mountain; through the community of Mormon Lake; and back to FH-3 on the southeast side of the lake. The communications site towers are not visible from FR 90 except in the area south of the Mormon Lake Village near the FH-3 intersection. This is because the road for the most part is located at the base of the mountain and the top where the towers are located is not visible. Both FH-3 and FR 90 are high-use primary travel routes in the area. The maps show that the mountain is seen as background from the west and northwest where no primary travel routes exist. The Sensitivity level for the area is 1, with the scenic quality of the landscape being Common (Class B). The Visual Quality Objective for the whole mountain is Partial Retention, meaning management activities remain visually subordinate to the characteristic landscape. The existing towers at MMCS during daylight hours are not a dominant visual feature as viewed from FH-3, FR 90 and Mormon Lake Village because of the distance from these view points and the size of the Mormon Mountain. The one FAA compliant lighted tower is visible at night but is otherwise subordinate to the landscape.

Environmental Consequences – Visual Quality

Alternative 1 – No Action No changes in the current visual quality of the project area will immediately result from the No Action Alternative.

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Alternative 2 – Proposed Action Given that the MMCS location is more than 3 miles from the view points of concern at FH-3 and FH 90 and more than 5 miles from the community of Mormon Lake; the proposed activities which are predominately the introduction of additional facilities such as buildings and towers would not represent changes that would be evident to the casual observer. The proposed taller towers as seen from FH-3, FR 90 (the determinant viewing perspective in this instance) and the Mormon Lake Community would therefore technically meet the intent of the Forest Plan visual quality objectives. Indication and conclusions from observations along FH-3 FR 90, and the Mormon Lake Village area is that the new tower and subsequent taller towers will be slightly more visible and would introduce a small additional vertical element to the view from FH-3 as seen by people traveling on FH-3 east of Mormon Lake and in the Lake Mary area. The additional element would be dwarfed by the landscape of the area, but it would add another "unnatural" element to the scenery as seen from this major travel route and from the residential area of the Mormon Lake. However the additional element would likely not be evident to the casual observer. Authorizing 280 foot AGL new or replacement towers next to the existing towers would be appropriate because there are already similar tall structures in place and it would be less of an addition of an unnatural element than placing additional towers in a new location on Mormon Mountain or upon other mountain tops in the area. Additional towers and/or replacement towers and extension of existing towers up to the 280 foot AGL height limit will add a small, but incremental vertical element to the view from various points on FH-3 and the community of Mormon Lake. MMCS is outside the ½ mile “Retention” zone buffer for FH-3 and FR 90 prescribed in the CNFLMP. The taller towers are not expected to move the visual classification downward from the existing condition and therefore the proposed action would be consistent with Forest Plan direction for visual quality management.

Photo 1. View as seen from FH-3 at Lake Mary. (Photo dated 10/20/08)

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36 Environmental Assessment for Mormon Mountain Communications Site, Coconino NF

Photo 2. View through zoom lens from FH-3 at Lake Mary showing towers on mountain top horizon. (Photo dated 10/20/08)

Photo 3. View from Mormon Lake Overlook. (Photo dated 10/20/08)

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3.8 Cultural Resources Northland Research, Inc. has conducted a Class I records search at the Coconino National Forest (CNF) Supervisor’s Office in Flagstaff to determine if MMCS had been included in previous cultural resources surveys and whether any cultural resource sites had been recorded in the area. The records of CNF indicate that the area within the proposed MMCS boundary had been included, in its entirety, in two previous surveys in which no cultural resource sites were found (Klinner et al. 1993; Nelson 1989). Because the area within the proposed MMCS boundary has been previously surveyed and clearance granted for cultural resources no further action or tribal consultation is required.

Affected Environment – Cultural Resources The cultural resource survey determined that no previously known or unknown archaeological sites or other cultural properties occur within the 11.7 acre area. Forest records also indicate that no known archaeological sites or other cultural resources occur at this specific location. Proper management practices will be maintained during construction should any archaeological or cultural material be found.

Environmental Consequences – Cultural Resources

Alternative 1 – No Action There are no direct, indirect, or cumulative impacts to cultural resources because no activities would occur.

Alternative 2 – Proposed Action The Proposed Action would not have any direct, indirect, or cumulative impacts on cultural resources because ground disturbing activity would occur in an area where no cultural resources are present.

3.9 Air Quality

Affected Environment The U.S. Environmental Protection Agency (EPA) established National Ambient Air Quality Standards (NAAQS) for six criteria pollutants (ground level ozone [O3], carbon monoxide [CO], nitrogen dioxide [NO2], sulfur dioxide [SO2], particulate matter, and lead). According to the EPA website (http://www.epa.gov/region9/air/), northern Arizona meets all NAAQS; therefore, air quality in the project area is good.

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38 Environmental Assessment for Mormon Mountain Communications Site, Coconino NF

Environmental Consequences – Air Quality

Alternative 1 – No Action Under the No Action Alternative, no construction would occur on the project, and no impacts to air quality would result from the alternative.

Alternative 2 – Proposed Action Short-term and temporary air quality impacts would result from construction-related activities and would include fugitive dust and exhaust emissions from construction equipment. Construction would be of relatively short duration and the air-pollutant emissions would be dispersed relatively quickly; therefore, air quality standards would not be approached or exceeded. Prescribed burning of the fuels would generate small levels of smoke and be monitored to insure air quality standards are met. The proposed project would not generate any air pollutants after completion of the construction and fuel treatment activities.

Cumulative Effects – Air Quality

Alternative 1 – No Action Implementation of the No Action Alternative, along with past, present and reasonably foreseeable actions, would have no cumulative effects on air quality.

Alternative 2 – Proposed Action Cumulative impacts on air as a result of the Proposed Action are expected to be directly related to the short-term construction. Other projects that may occur in the general area and affect air quality include prescribed burning. Air quality from prescribed burning is monitored to ensure state air quality standards are met. The small levels of air quality impact from the project construction/burning activities when combined with other prescribed burns would have minimal increase to air quality impacts and expected to remain well within standards.

3.10 Noise

Affected Environment The Proposed Action is located on the Coconino National Forest. The closest private landowners are located over 2 miles to the southeast. The nearest business is located approximately 1 ½ miles to the east of the communications site. Mormon Lake town site and Mormon Lake Lodge are located approximately 5 miles to the southeast. Interstate 17 is located approximately 9 miles to the west.

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Environmental Consequences – Noise

Alternative 1 – No Action Under the No Action Alternative, no construction would occur on the project, and no impacts from noise would result from the alternative.

Alternative 2 – Proposed Action Noise levels resulting from the proposed project would be almost entirely due to construction related activities, which would result in a temporary increase in noise levels during daytime hours in the immediate vicinity of MMCS. Noise associated with construction activities will be limited to the time period between October 1 and March 30 due to the MSO construction timing restriction.

Cumulative Effects – Noise

Alternative 1 – No Action Implementation of the No Action Alternative, along with past, present, and reasonably foreseeable actions, would have no cumulative effects from noise.

Alternative 2 – Proposed Action Cumulative impacts from noise, as a result of the Proposed Action, are expected to be directly related to the short-term construction period. Implementation of the Proposed Action, along with past, present, and reasonably foreseeable actions, would have minimal cumulative effects from noise. There are no cumulative noise impacts because there are no other past, present, and reasonably foreseeable actions generating noise that will result in increased noise levels in the immediate vicinity of MMCS. Because the construction period is of short duration and other future projects will not coincide with the proposed action, there will be no cumulative impacts associated with noise.

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Chapter 4 - Consultation and Coordination

Public involvement is described in Chapter 1.

Following agencies were consulted:

U.S. Fish and Wildlife Service

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Chapter 5 - References

Arizona Department of Commerce (2006). Flagstaff: Community Profile. Retrieved October 24, 2006 from http://www.azcommerce.com.

Council on Environmental Quality (1997). Environmental Justice: Guidance Under the National Environmental Policy Act. Executive Office of the President.

EcoPlan Associates, Inc (2009). Biological Evaluation, Forest Service Sensitive Species, Mormon Mountain Communications Site, Coconino National Forest, Arizona. Northland Research, Inc.

EcoPlan Associates, Inc (2009). Biological Evaluation Plant and Wildlife Specialist’s Report, Mormon Mountain Communicatins Site, Coconino National Forest, Arizona. Northland Research, Inc.

EcoPlan Associates, Inc (2009). Biological Evaluation for Federally-listed and Proposed Species, Mormon Mountain Communications Site, Coconino National Forest, Arizona.

Federal Communications Commission, Office of Engineering and Technology (1999). Questions and Answers about Biological Effects and Potential Hazards of Radiofrequency Elcetromagnetic Fields. OET Bulletin 56, Fourth Edition.

Office of Governmentwide Policy, GSA (1997). Placement of Commercial Antennas on Federal Property. GSA Bulletin FPMR D-242, Federal Register, Vol. 62, No. 115, June 16, 1997.

United States Department of Agriculture (1987). Coconino National Forest Plan. Coconino National Forest, Southwestern Region.

United States Department of Agriculture (1987). Environmental Impact Statement for the Coconino National Forest Plan. Coconino National Forest, Southwestern Region.

United States Department of Agriculture (2001). Interstate 17 Wireless Communication System Proposal Environmental Assessment, Orme Road to Flagstaff, Coconino National Forest. Coconino National Forest, Southwestern Region.

United States Department of Agriculture (2004). Draft Environmental Impact Statement for Integrated Treatment of Noxious and Invasive Weeds, Coconino Kaibab, and Prescott National Forests and Coconino, Mojave, and Yavapai Counties, Arizona. Coconino National Forest, Southwestern Region

United States Environmental Protection Agency (n.d.). Air Quality Maps. Retrieved November 29, 2006 from http://www.epa.gov/region9/air/maps/.

U.S. Department of Agriculture, Forest Service. National Forest Landscape Management: Volume 2, Chapter 1: "The Visual Management System." Agriculture Handbook 462. Washington, DC: U.S. Department of Agriculture; 1974. 47 pages. Agriculture Handbook (AH) 462, has been superseded by AH 701, “Landscape Aesthetics, A Handbook for Scenery Management.”

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Chapter 6 – List of Preparers

USDA Forest Service, Coconino National Forest Sheila Sandusky FS ID Team Leader Sandra Nagiller Forest NEPA Coordinator Jim Beard Landscape Architect Henry Provencio Wildlife Biologist Beale Monday Fire and Fuels Planner Peter Pilles Archaeologist

Northland Research, Inc. Ken Jacobs Project Manager Ami S. Barrera GIS, Editor Steve Dosh Archaeologist Ron Van Omerran Biologist - EcoPlan Associates Inc.