Each issue against the decision, unreviewed

• PLAN’s match, not yet checked by a personThe EA admits that the Big Blakely Creek-Lake Ouachita sub-watershed will be elevated from Low to Moderate watershed condition risk under the Proposed Action, and that even spreading implementation across five years still yields a Moderate risk.

  The EA admits that the Big Blakely Creek-Lake Ouachita sub-watershed will be elevated from Low to Moderate watershed condition risk under the Proposed Action, and that even spreading implementation across five years still yields a Moderate risk.

  The document describes Moderate risk as characterized by 'persistent environmental effects which can change the hydrologic system with observable changes for as long as the causing action persists.' Yet the agency does not explain why this persistent, lasting impairment to beneficial uses does not rise to the level of significance requiring an EIS. The agency should prepare an EIS or provide a written significance determination that directly addresses why a persistent watershed condition change is not a significant effect under NEPA.

  A hole PLAN found in the agency’s own analysis

  “Soil and water impacts from the proposed action will be minor and localized, including temporary disturbance to soil structure or organic matter, small patches of high severity fire effects, short term erosion following heavy precipitation, and limited short term temperature changes in streams. These impacts will remain within Forest Plan thresholds”

  The agency’s own words, FourcheValleyFinalFONSI ↗, Determination of No Significant Impacts · PLAN’s match, unchecked, an answer in part

• PLAN found no answer, not yet checked by a personThe EA identifies only one issue for detailed analysis: herbicide safety.

  The EA identifies only one issue for detailed analysis: herbicide safety.

  Forest policy requires analysis of alternatives to herbicide use, and the document notes this is why the No Herbicide alternative was developed. However, the No Herbicide alternative actually has a higher Revenue/Cost Ratio (2.91 versus 2.77) and lower costs than the Proposed Action, yet the agency selected the Proposed Action. The document never reconciles why the economically superior and lower-risk alternative was not chosen, stating only that manual release 'usually requires re-treatment.' That single unsupported assertion does not constitute a reasoned explanation for rejecting the cheaper, higher-ratio alternative. The agency should provide a written, reasoned explanation for selecting the Proposed Action over the No Herbicide alternative given the financial data in Table 3.1.

  A hole PLAN found in the agency’s own analysis

• PLAN found no answer, not yet checked by a personThe EA uses SERA risk assessments dated as far back as 2004 and 2011 to evaluate herbicide hazards, and relies on rat and bluegill as analogs for listed bat species, fish, and mussels.

  The EA uses SERA risk assessments dated as far back as 2004 and 2011 to evaluate herbicide hazards, and relies on rat and bluegill as analogs for listed bat species, fish, and mussels.

  For triclopyr applied to bluegill the document itself states toxicity 'varies greatly with formulation' and 'appears to be somewhat toxic with great variation,' yet the EA draws a conclusion of low risk without disclosing which formulation was tested relative to the formulations proposed for use. The agency should identify the specific triclopyr formulation proposed for use in the project, confirm that the SERA data apply to that formulation, and update the risk assessment with any more recent data before relying on it to support a finding of no significant impact.

  A hole PLAN found in the agency’s own analysis