City Comment on US Forest Service Proposed Action - Flagstaff Watershed Protection Project.

The Coconino National Forest and the City of Flagstaff announced Monday April 8^th 2013 that the Flagstaff Watershed Protection Project (FWPP) Proposed Action (PA) was available for public review and comment.  The official Notice of Intent (NOI) was published in the Federal Register Thursday Apr 11^th 2013, initiating the project’s formal 30-day scoping period.  Thus, the end of the scoping period will be May 13^th 2013 (the 30 days has to end on a weekday, so it’s actually 32 days long).
 
Information on the project is posted on the Coconino National Forest Project website under “Flagstaff Watershed Protection Project” at http://www.fs.usda.gov/projects/coconino/landmanagement/projects.  The PA is relatively short – 34 pages. A copy of the PA is also attached to this Staff Summary.  
 
Per the National Environmental Planning Act (NEPA), only those who provide specific written comments during this formal scoping period and/or during later comment periods will have “standing” to object later in the planning and decision process.  Official comments must be postmarked no later than May 13^th 2013 to be considered part of the US Forest Service project record.

Although the City is not required to provide written comment during the scoping period currently underway, it is in our best interest to do so.  All comments are part of the official project record, and are visible to anyone seeking information or examining the record. A comment at this point advocates for the wish of the voters and amplifies our corporate support for the project to any and all parties.  Should the project be litigated by a third party following the Record of Decision to be issued by the US Forest Service next fall/winter prior to full-scale field implementation, a comment provides context for later potential City action(s).

An official comment letter, does not by itself, obligate the City to expend any of the voter-approved $10 million bond funds for individual actions on US Forest Service lands within the project area.  While it does signal our committment to do so at a later date, those obligations will come to Council for consideration and action over time, in the form of individual Project Supplemntal Agreements (SPA).

The Flagstaff Watershed Protection Project (FWPP) supports the following Council goals:

 4.   Complete Rio de Flag
 5.   Retain, expand, and diversify economic base
 6.   Complete Water Policy
 11. Effective governance

In June 2012, Council approved Question #405 for the November 2012 special authorization bond election which was subsequently approved with a 73.6% vote.  In January 2013, Council approved three agreements with the US Forest Service for forest treatments on federal lands covered by the FWPP.  In March 2013, City Council and the County Board of Supervisors met in joint-session where the FWPP was discussed.  In April 2013, Council approved project related agreements with the State of Arizona and Greater Flagstaff Forests Partnership.

1.  Submit attached draft comment as written, thus placing an official formal written comment by the City in the US Forest Service project record;
2.  Revise the attached draft comment and submit a modified version;
3.  Do not submit a comment, thus not providing an official written comment by the City for the US Forest Service project record.

In summary, the PA - which covers both the Dry Lake Hills area (Rio de Flag) and Lake Mary Watersheds - discusses and/or contains the following features:
1) Existing conditions of the area, and expected fire behavior if left untreated;
2) Desired condition of the area (following treatment) and expected fire behavior once treated;
3) Treatment descriptions and objectives;
4) Implementation methods;
5) Placement of a permanment campfire ban in the Dry Lake Hills area;
6) Maps and tables;
7) Other issues (roads, forest plan amendments, monitoring, etc); and
7) Invite to public to provide comment.