Here is additional information. Please let me know if I can answer questions:

Aztec Ruins National Monument is accepting public comments on its General Management Plan (GMP), which will guide park actions for the next 10-15 years.

The plan calls for removing orchards and scattered fruit trees throughout the park, followed by revegetation with native species. The orchards consist of some 175-200 pear and apple trees from 50 to 100 years old, in varying degrees of health. Some trees are located west of the West Ruin, the primary ruin that visitors see, others are located near the Animas River, out of view of visitors. Historically the Animas River valley was a prolific and important fruit growing region. Most of the old orchards in the region have disappeared.

The GMP presents only two alternatives for orchard management: 1. continue existing conditions, ie. provide minimal care and some irrigation 2. remove all trees (preferred alternative). An alternative to “restore” the orchards and maintain them was dismissed from analysis.

Those interested can:

Obtain the full plan at: http://www.nps.gov/azru/parkmg.....GMP_EA.pdf

Obtain a newsletter that summarizes the alternatives, the preferred alternative, and environmental impacts at: http://www.nps.gov/azru/parkmgmt/upload ... _web-2.pdf

Submit comments until April 10 at: http://parkplanning.nps.gov/azru.

Those who comment can request to be placed on the park mailing list for future communications about the orchards.

The National Park Service is not required to consider comments that are not “substantive,” such as comments in favor or against the proposed action or alternatives. Substantive comments present reasonable alternatives for consideration, address accuracy of information, and address the adequacy of environmental analysis.

Substantive comments about this issue include the following:
--The historic and scientific values of the orchards need to be identified for an accurate impact analysis.
--A full description of all the orchards, the tree varieties, present conditions of the orchards, past and present care, and accurate costs based on work records are needed for an accurate analysis.
--The reasons to dismiss the alternative to restore and maintain the orchards from further analysis are not adequate because:
1. Scientific information specifically addressing orchard irrigation effects on ruins preservation is not evident.
2. Park mission goals and fundamental values cited in the GMP do in fact support the presence of the orchards.
3. The assertion that visitors are “distracted” by the orchards is not supported by evidence. Moreover, the presence of the orchards supports a primary interpretive theme.
4. Estimated costs for this proposed action (initially $55,000 to restore trees, thereafter $13,000 annual maintenance) and comparative costs of the preferred alternative ($20,000 to remove trees and revegetate with native species) are unrealistic and not substantiated.
5. The use of partnerships to assist in managing the orchards was not considered.
6. The assertion that the orchards represent a low priority resource for funding is not a valid reason for dismissing the action from further analysis.
7. The diversity of locations and varieties of the trees were not recognized in the application of the reasons to dismiss the alternative.

--The plan does not consider a full range of alternatives for managing the orchards. A range of reasonable alternatives must be considered, such as: varying the levels of treatment that take into account the different locations of the trees, alternate irrigation strategies if orchard water is scientifically shown to be unacceptable to ruins preservation (watering a portion of the trees, using drip irrigation, etc.), establishing partnerships to assist in their care.
--Orchards should be treated as an historic resource throughout the plan, pending a Determination of Eligibility for listing on the National Register of Historic Places.
--The impact topic of historic resources (including the orchard) should not have been eliminated from the environmental analysis because there could be an adverse effect by removing historic resources such as the orchard.
--The environmental impact analysis is inadequate. It does not rely on current and adequate scientific information; does not fully consider impacts on wildlife, threatened and endangered species, vegetation, and historic resources (orchards); inadequately assesses impacts on visitors; and incorrectly applies impact measurements.
--The decision to remove the orchards is a site-specific decision that is far too complex and requires a detailed analysis that is inappropriate in a general management plan.
--The health of the orchards should be maintained at a status quo until a full range of alternatives are considered and an adequate environmental impact analysis is prepared. Adequate watering of all trees should prevent them from undergoing stress.

It is unknown whether there are heirloom varieties, because that research has not been done. When I was there, I was working on partnering with a university to get some basic genetic research done to be able to answer this question. Apparently this work was not done. The possibility for the presence of heirloom varieties is high--there seems to be a variety of apple trees--they flower at different times, and when they bear fruit, there is a difference in the quality and appearance of fruit among trees. The apples are probably at least 100 years old. The younger pear orchard (about 55 years), which constitutes most of the orchards, are probably one variety.

This is one of the problems with the analysis. The scientific value--genetic diversity, presence of heirloom varieties, etc.--is unknown. Therefore the environmental impact analysis was not accurate given this inadequate information.

Thanks for the comment.

It is very unusual (aside from violating Section 106 of the National Historic Preservation Act) for a National Park Service unit to make a decision to remove a resource that is possibly eligible for the National Register of Historic Places, as are the orchards at Aztec Ruins, without first conducting a determination of eligibility and consulting with the State Historic Preservation Office.

I was told by an orchardist in New Mexico that there are some very old trees--possibly close to 400 years--planted by the Spanish missionaries at Salinas Pueblo Missions near Mountainair, NM. They are in very poor health, however, and the orchardist was working with the park to propagate the genetic material.