Stop logging and road work in Black Hills National Forest
Roby Forest Management Project
U.S. Forest Service· Hell Canyon Ranger District, Black Hills National ForestU.S. Forest Service project page ↗
Forest ServiceWe track this on the agency’s own system of record, where most on-the-ground decisions live.
The groups on this fight
4 groups work South Dakota
By footprint, from the same match the STAND matchmaker runs; none is linked to this decision in our record yet. Give straight to them; nothing routes through us.
- Badlands Natural History Association
Works South Dakota: they work only in South Dakota.
- Honor the Earth
Works South Dakota: on the ground in South Dakota.
- Intertribal Buffalo Council
Works South Dakota: based in Rapid City, working South Dakota.
- Wind Cave National Park Friends Group
Works South Dakota: they work only in South Dakota.
Every group above is on STAND for Public Lands, with its court record, its filings and who backs it.
The Forest Service plans to log, build roads, and alter habitat across the Hell Canyon Ranger District.
What’s at risk
Trees, watersheds, and wildlife habitat in the Black Hills National Forest face permanent change from timber harvest and road construction. Once logging and road work are completed, those landscape changes cannot be undone.
If this goes through
Timber harvest and new road infrastructure will alter the Hell Canyon Ranger District in ways that cannot be reversed, and you lose your right to formally object if you do not comment with your name before July 15, 2026.
Our plain-English read of the official notice ↗. Check it against the agency’s own words below.
The agency’s case, tested
What the agency argues, and whether its own record backs it
- 3
- Hold up
- 3
- No support given
- 2
- Never analyzed
The Forest Service proposes commercial timber harvest on up to 9,677 acres, thinning and conifer removal on tens of thousands more, prescribed burning on up to 46,073 acres, and road building, repair and closures west of Custer, South Dakota. It says this will cut fire hazard, boost timber production as federal direction requires, and restore riparian areas, meadows, a research natural area and roads.
“The proposed action would result in beneficial effects by proactively managing the landscape to increase resilience and safety.”
Discussion
Each Ask below goes into your letter when you write it with PLAN on this page, matched to what you tell it about how this land reaches you.
Effects
No support given
Soil disturbance won't exceed the Forest Plan's 15 percent limit or cause long-term loss of soil productivity.
The agency says almost all soils rate high for restoration potential, there are no known areas of concern, and operations would occur on dry or frozen soils with slash mats on steep slopes. It also cites Black Hills monitoring finding detrimental levels uncommon and a study showing zero to 12 percent disturbance with steep-slope methods. But it names soil disturbance in combination with other activities as a substantive issue, admits monitoring hasn't occurred recently in the area, and gives no existing or projected disturbance figures after 16,052 acres of harvest since 2006 in Table 7. So closeness to the 15 percent limit can't be checked.
AskEstimate existing detrimental soil disturbance by land unit, including past timber sales, and project totals with this action against the 15 percent Forest Plan standard.
The agency’s words, the record and the law +Hide the words
The agency says
“Because the proposed action includes design criteria protecting soil health and would be implemented consistent with Forest Plan standards and best management practices, it would not result in loss of long-term soil productivity or exceed regulatory thresholds.”
Soil Productivity
Elsewhere in the same document
“Soil disturbance monitoring has not occurred recently in the project area.”
Soil Productivity
“Concern was raised that the proposed action, in conjunction with past activities in the project area, could cause detrimental soil disturbance levels to approach this threshold in some areas.”
Soil Productivity
The law
“Resource plans and permits, contracts, and other instruments for the use and occupancy of National Forest System lands shall be consistent with the land management plans.” National Forest Management Act, 16 U.S.C. 1604(i) ↗
Effects
No support given
Lower wildfire risk will prevent enough future weed spread to outweigh the weed increase the project causes.
The agency cites a study that severely burned forests are prone to invasion. It quantifies the project's side: priority weeds from 29 to as high as 56 acres in five years, and non-priority weeds from about 2,300 to as many as 4,400 acres. It never estimates how many weed acres lower fire risk would avoid, so the weighing has nothing on the other side.
AskEstimate weed acres expected after severe wildfire without action and compare them to the project's projected increase, and explain weed treatment funding beyond the two to five year monitoring window.
The agency’s words, the record +Hide the words
The agency says
“With implementation of proposed weed control measures, this positive effect of fire hazard reduction would be expected to outweigh the potential harm.”
Non-native Invasive Plants
Elsewhere in the same document
“Non-priority species could increase to as many as 4,400 acres.”
Non-native Invasive Plants
“Design criteria described starting on p. 16, including avoidance of areas infested with priority weed species, cleaning of equipment, prompt reporting of new infestations, and control actions, are expected to reduce but not eliminate the potential for additional infestation.”
Non-native Invasive Plants
Effects
No support given
Cultural resources, including tribal sacred sites, will be protected by avoidance.
The agency has finished inventory and consultation on 18,219 acres in the north, with 16 areas to protect by avoidance and a finding of no adverse effect. It commits that implementation won't occur until inventory and Section 106 consultation are complete, under a phased approach allowed by a 2019 programmatic agreement. Still, inventory in the southern part, which makes up most of the National Forest acres, is in progress, its protection measures aren't written yet, and tribal consultation on sacred sites is ongoing, so protection there can't be confirmed from this text.
AskComplete the southern inventory and tribal consultation before any finding of no significant impact, and explain how sacred sites not eligible for the National Register would be identified and protected.
The agency’s words, the record and the law +Hide the words
The agency says
“Identified cultural resources would be protected from adverse impacts by avoidance during project implementation.”
Relevant Executive Orders
Elsewhere in the same document
“Inventory of historic properties and Section 106 consultation have been completed on 18,219 acres in the northern part of the project area, resulting in 16 areas to protect (see p. 17).”
Heritage and Cultural Resources
“Similar measures will be developed for the southern part of the project area before project implementation (see p. 27).”
Heritage Resources Protection
The law
“shall take into account the effect of the undertaking on any historic property.” National Historic Preservation Act, 54 U.S.C. 306108 ↗
What the document never analyzes
Not analyzed
Climate and carbon effects
The project would burn up to 46,073 acres and harvest thousands of acres of mostly mature pine, yet emissions are discussed only for Clean Air Act smoke compliance.
Searched all 45 pages for ‘climate’, ‘carbon’, ‘greenhouse’. None appear.
AskEstimate carbon released by burning and harvest and how long regrowth would take to recover it, and discuss how changing climate affects fire and regeneration assumptions.
Not analyzed
Groundwater and spring flows
The area has 185 springs, 195 wetlands and a limestone plateau, yet the water analysis covers only surface streams and sediment.
Searched all 45 pages for ‘groundwater’, ‘aquifer’, ‘recharge’. None appear.
AskAnalyze how thinning, burning and road work could affect groundwater recharge and flows at the 185 springs.
Where its own record backs the agency
AuthorityThe National Forest Management Act and Forest Plan allow commercial harvest on lands unsuitable for timber production to meet non-timber goals.Why it holds +
The document cites 36 CFR 219.14 and the Forest Plan for allowing unscheduled harvest on unsuitable lands to meet multiple-use goals. Table 20 ties 1,188 of the 1,649 acres to fire hazard, old growth and aspen goals. For the 461 acres of restrictive topography, the table points back to the purpose and need, which includes fire hazard reduction, meadow restoration and other non-timber goals. It also says advanced logging would make harvest feasible there. A reader may want a clearer tie for those 461 acres, but the legal point the claim makes is supported.
The agency says
“While the Forest Plan identifies certain lands as “unsuitable,” NFMA and the Forest Plan allow unscheduled commercial harvests on such sites, including low-productivity areas and old-growth landscapes, to achieve multiple-use objectives like hazardous fuels reduction.”
National Forest Management Act
Its own record backs it
“Eleven percent of the project area consists of forest considered to be unsuitable for timber production (Forest Plan Appendix G-1).”
Timber Production
EffectsThe project would lower fire hazard compared with doing nothing.Why it holds +
Table 19 shows very high hazard falling from 4 to 3 percent of pine acreage and high hazard from 27 to 15 percent, with medium rising from 66 to 82 percent. The existing ratings leave out recent wind-damage fuels, so the baseline may understate hazard, but the document's own figures back the direction of the claim.
The agency says
“The proposed action would decrease fire hazard as compared to the effects of taking no action (Table 19).”
Fire Hazard
Its own record backs it
“Approximately four percent of pine acres in the project area are currently rated as having very high fire hazard.”
Fire Hazard
“These figures are based on verified stand structural stage and size class but do not account for scattered areas of hazardous fuels created by recent wind damage, especially in the southern part of the project area.”
Fire Hazard
EffectsWater quality will see no more than minimal changes in temperature and sediment.Why it holds +
The agency cites monitoring reports showing best management practices generally prevent or minimize road sediment, notes aquatic management zone buffers, and plans 16 miles of road closures. The baseline supports low risk: three main watersheds are functioning properly, no streams are listed as impaired, and 97 percent of stream miles are ephemeral or intermittent.
The agency says
“With full implementation of project-specific design features, Forest Plan standards and guidelines, watershed conservation practices, and best management practices, the proposed action would be expected to cause no more than minimal changes to water temperature, sedimentation, and sediment yields.”
Water Quality
Its own record backs it
“Proposed road construction, improvement, and maintenance would be conducted in accordance with best management practices, which have been shown to generally prevent sedimentation or reduce it to negligible levels (USDA Forest Service 2020, 2026b).”
Water Quality
“No streams in the project area are listed as impaired by the State of South Dakota.”
Water Quality
Read from the agency’s own decision document ↗, all 45 pages. Every quote is checked word for word against it, a claim marked contradicted stands on a quote from the same document, and a second reading argued the agency’s side of every verdict before it was published. The verdicts are our reading; the quotes are the agency’s. A court can set aside agency action it finds “arbitrary, capricious, an abuse of discretion, or otherwise not in accordance with law” (5 U.S.C. 706(2)(A) ↗), which is why these gaps are worth putting in the record.
What to say
Make these points, in your own words
- I oppose this action as proposed, and I ask the agency to weigh the specific harms below.
- The EA acknowledges that the project is operating under an emergency authority that explicitly strips the normal pre-decisional objection process and limits alternatives to only the proposed action and no-action, yet the agency simultaneously claims this EA is adequate to support a FONSI. The single-alternative structure is the direct product of a procedural shortcut, not a reasoned determination that no other alternative warrants study. Table 8 shows that several structural stages are already below Forest Plan objectives (for example, HSS 3B at 3.3% against a 15% objective in MA 5.1), and alternative harvest intensities or spatial configurations could move those stages toward objectives while still reducing fire hazard. The agency should either justify in writing why no middle-ground alternative was considered on the merits, or prepare an EIS with a full range of alternatives as NEPA…
- The EA admits that outside known goshawk nest area stands, the proposed action 'would further decrease potential nesting habitat and retain few stands that could provide near-future preferred habitat in the event of loss of existing habitat,' yet it reaches only a 'may adversely impact individuals but not likely to result in a loss of viability' conclusion with no quantitative analysis of how much habitat would be removed or what buffer of future habitat would remain. The document provides no acreage of goshawk foraging or nesting habitat before and after treatment, no connectivity analysis, and no discussion of cumulative loss from the 16,052 acres already harvested since 2006 (Table 7). The agency should provide a site-specific habitat accounting table and explain, with numbers, why viability is not threatened before finalizing the decision.
- The EA states that 'soil disturbance monitoring has not occurred recently in the project area,' yet it proceeds to conclude that the proposed action will not exceed the Forest Plan's 15-percent detrimental disturbance threshold (Forest Plan standard 1103). Without a current baseline, the agency cannot know how close existing disturbance already is to that threshold, especially given that Table 7 documents 16,052 acres of commercial harvest since 2006. Relying on design criteria and references to Pacific Northwest studies to substitute for actual site monitoring is an unreasoned leap. The agency should conduct or require current soil disturbance monitoring across the project area and incorporate those findings before signing a FONSI.
- The EA states that tribal consultation was initiated on June 29, 2026, and that 'consultation is ongoing,' yet the FONSI signature block and activities approved are both listed as 'TBD' pending the public comment period. The document provides no description of what tribes have communicated, what concerns have been raised, or how those concerns will be resolved before implementation. This is especially significant because cultural resource inventory for the southern part of the project area is also still incomplete. Approving the action before consultation is concluded and before Section 106 inventory is finished in the south violates the spirit of government-to-government consultation and EO 13007. The agency should complete tribal consultation and southern Section 106 inventory and disclose their outcomes before making a final decision.
Show all 12 points from the document
- The EA proposes prescribed broadcast burning on up to 46,073 acres but states that 'exact locations would be determined at a later date with review by resource specialists.' It also states that shaded fuel breaks range from 285 to 2,289 acres depending on whether other silvicultural treatments occur. These are not minor details; they represent the majority of the project footprint and the primary mechanism for achieving the stated fire-hazard reduction purpose. Deferring location decisions to post-NEPA review means the public has no meaningful opportunity to comment on where burning will occur relative to residences, water sources, sensitive plant communities, or cultural sites. The agency should either fix the burn unit boundaries in the EA or prepare a supplemental analysis once locations are determined, before implementation.
- The EA concedes that the project's site index averages 53.2, well below the Black Hills National Forest average of 68.6, and that 11 percent of the project area is unsuitable for timber production. It then proposes 461 acres of harvest on lands with 'restrictive topography' to make 'previously inaccessible or uneconomical' areas accessible (Table 20), while also authorizing up to 478 acres of harvest on slopes of at least 40 percent. NFMA requires that timber harvests on unsuitable lands be justified by multiple-use objectives, but the EA's rationale for the topographically restricted acres is simply that advanced logging techniques now make harvest 'feasible,' which is an economic justification, not an ecological one. The agency should provide a written multiple-use justification for each category of unsuitable-land harvest that goes beyond cost and access feasibility.
- The EA acknowledges that stand age is used as a proxy for Culmination of Mean Annual Increment (CMAI) 'due to limited recent stand inventory data,' and that all stands 120 years or older are assumed to have reached CMAI. NFMA requires that final removal harvests occur only after CMAI. Using a blanket age proxy instead of actual inventory data for a project authorizing 9,677 acres of commercial harvest, including overstory removal and shelterwood seed cuts, means the agency cannot confirm that it is meeting a statutory requirement. The agency should either conduct updated stand inventory to verify CMAI for stands proposed for final-removal prescriptions or explain in detail why the age proxy is scientifically valid for each prescription type used.
- The EA states that non-priority invasive plant species 'could increase to as many as 4,400 acres' under the proposed action, compared to a current documented extent on approximately 2,300 acres. That is a projected near-doubling of non-priority weed coverage, yet the agency dismisses this impact by asserting that fire hazard reduction benefits would outweigh the harm. No quantitative comparison is provided: the EA does not estimate how many acres of weed infestation a severe wildfire would cause, nor cite a study showing that the specific weed species present respond more to fire than to mechanical disturbance. The agency should provide a quantitative comparison or cite site-specific evidence before concluding that the tradeoff favors the proposed action.
- Table 22 shows that habitat structural stages 4A and 4B would move further from Forest Plan objectives in both Management Areas 5.1 and 5.4 under the proposed action, with MA 5.1 HSS 4A increasing by 2,400 acres above its 25-percent objective. The EA acknowledges this directly but offers no substantive explanation for why moving these stages further from objectives is acceptable or how it squares with the NFMA consistency requirement. The statement that 'the proposed action would cause most structural stages to move toward objectives or result in no change' is accurate only if stages already below objective are counted, but it obscures the overstocking of 4A. The agency should explain specifically how approving an action that worsens compliance with Forest Plan structural-stage objectives in both Management Areas is consistent with NFMA.
- The EA identifies only two substantive issues for formal analysis: soil disturbance and weed infestation. It does not identify effects on the four documented American goshawk territories, cumulative effects of prior harvests, smoke impacts on nearby communities, or water quality in the three main watersheds as substantive issues requiring quantitative analysis. The interdisciplinary team's screening therefore determines the scope of analysis in a way that excludes several topics where the document's own text reveals real uncertainty. For example, the Clean Air Act compliance section says the project 'is expected to contribute to emissions during implementation' with no quantification, and smoke design criteria defer assessment to burn-plan preparation. The agency should expand the substantive issues list to include air quality impacts on nearby communities and cumulative wildlife…
- Say something only you can say. The law requires the agency to consider and respond to substantive comments, and specifics are what make a comment substantive.
In the agency’s own words
The Roby Forest Management Project proposes timber harvest, fuel reduction, prescribed fire, road improvements, meadow restoration, and riparian restoration activities.
Did the agency answer?
18 issues are on this record. The agency has not published its decision document yet, so each one stays pending until the agency answers.
Issues on the record, awaiting the decision
- PendingThe document states most streams in the project area are ephemeral or intermittent rather than perennial flowing water.
The document states most streams in the project area are ephemeral or intermittent rather than perennial flowing water.
- PendingThe document describes the Fanny/Boles RNA as 313 acres along a ridgeline with exposed limestone outcrops and small steep canyons of pine and juniper.
The document describes the Fanny/Boles RNA as 313 acres along a ridgeline with exposed limestone outcrops and small steep canyons of pine and juniper.
- PendingThe document asserts there are no snowmobile trails within the project area.
The document asserts there are no snowmobile trails within the project area.
- PendingThe document asserts there are no developed recreation areas, non-motorized trails, wilderness areas, or wilderness study areas in or near the project area.
The document asserts there are no developed recreation areas, non-motorized trails, wilderness areas, or wilderness study areas in or near the project area.
- PendingThe document asserts that aside from a short stretch of U.S.
The document asserts that aside from a short stretch of U.S. Highway 16, all roads in the project area are unpaved.
- PendingThe document places the Antelope Springs motorized trailhead at the northern end of the project area.
The document places the Antelope Springs motorized trailhead at the northern end of the project area.
- PendingThe document states four American goshawk territories have been documented as active nesting sites within the last seven years.
The document states four American goshawk territories have been documented as active nesting sites within the last seven years.
- PendingThe document states ponderosa pine dominates roughly 82 percent of the project area's land cover.
The document states ponderosa pine dominates roughly 82 percent of the project area's land cover.
- PendingTable 22 shows that habitat structural stages 4A and 4B would move further from Forest Plan objectives in both Management Areas 5.1 and 5.4 under the proposed action, with MA 5.1 HSS 4A increasing by
Table 22 shows that habitat structural stages 4A and 4B would move further from Forest Plan objectives in both Management Areas 5.1 and 5.4 under the proposed action, with MA 5.1 HSS 4A increasing by 2,400 acres above its 25-percent objective. The EA acknowledges this directly but offers no substantive explanation for why moving these stages further from objectives is acceptable or how it squares with the NFMA consistency requirement. The statement that 'the proposed action would cause most structural stages to move toward objectives or result in no change' is accurate only if stages already below objective are counted, but it obscures the overstocking of 4A. The agency should explain specifically how approving an action that worsens compliance with Forest Plan structural-stage objectives in both Management Areas is consistent with NFMA.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe EA acknowledges that the project is operating under an emergency authority that explicitly strips the normal pre-decisional objection process and limits alternatives to only the proposed action an
The EA acknowledges that the project is operating under an emergency authority that explicitly strips the normal pre-decisional objection process and limits alternatives to only the proposed action and no-action, yet the agency simultaneously claims this EA is adequate to support a FONSI. The single-alternative structure is the direct product of a procedural shortcut, not a reasoned determination that no other alternative warrants study. Table 8 shows that several structural stages are already below Forest Plan objectives (for example, HSS 3B at 3.3% against a 15% objective in MA 5.1), and alternative harvest intensities or spatial configurations could move those stages toward objectives while still reducing fire hazard. The agency should either justify in writing why no middle-ground alternative was considered on the merits, or prepare an EIS with a full range of alternatives as NEPA requires when a project of this scale may have significant effects.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe EA identifies only two substantive issues for formal analysis: soil disturbance and weed infestation.
The EA identifies only two substantive issues for formal analysis: soil disturbance and weed infestation. It does not identify effects on the four documented American goshawk territories, cumulative effects of prior harvests, smoke impacts on nearby communities, or water quality in the three main watersheds as substantive issues requiring quantitative analysis. The interdisciplinary team's screening therefore determines the scope of analysis in a way that excludes several topics where the document's own text reveals real uncertainty. For example, the Clean Air Act compliance section says the project 'is expected to contribute to emissions during implementation' with no quantification, and smoke design criteria defer assessment to burn-plan preparation. The agency should expand the substantive issues list to include air quality impacts on nearby communities and cumulative wildlife habitat loss, and provide quantitative analysis of each before issuing a FONSI.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe EA admits that outside known goshawk nest area stands, the proposed action 'would further decrease potential nesting habitat and retain few stands that could provide near-future preferred habitat
The EA admits that outside known goshawk nest area stands, the proposed action 'would further decrease potential nesting habitat and retain few stands that could provide near-future preferred habitat in the event of loss of existing habitat,' yet it reaches only a 'may adversely impact individuals but not likely to result in a loss of viability' conclusion with no quantitative analysis of how much habitat would be removed or what buffer of future habitat would remain. The document provides no acreage of goshawk foraging or nesting habitat before and after treatment, no connectivity analysis, and no discussion of cumulative loss from the 16,052 acres already harvested since 2006 (Table 7). The agency should provide a site-specific habitat accounting table and explain, with numbers, why viability is not threatened before finalizing the decision.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe EA states that 'soil disturbance monitoring has not occurred recently in the project area,' yet it proceeds to conclude that the proposed action will not exceed the Forest Plan's 15-percent detrim
The EA states that 'soil disturbance monitoring has not occurred recently in the project area,' yet it proceeds to conclude that the proposed action will not exceed the Forest Plan's 15-percent detrimental disturbance threshold (Forest Plan standard 1103). Without a current baseline, the agency cannot know how close existing disturbance already is to that threshold, especially given that Table 7 documents 16,052 acres of commercial harvest since 2006. Relying on design criteria and references to Pacific Northwest studies to substitute for actual site monitoring is an unreasoned leap. The agency should conduct or require current soil disturbance monitoring across the project area and incorporate those findings before signing a FONSI.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe EA states that tribal consultation was initiated on June 29, 2026, and that 'consultation is ongoing,' yet the FONSI signature block and activities approved are both listed as 'TBD' pending the pu
The EA states that tribal consultation was initiated on June 29, 2026, and that 'consultation is ongoing,' yet the FONSI signature block and activities approved are both listed as 'TBD' pending the public comment period. The document provides no description of what tribes have communicated, what concerns have been raised, or how those concerns will be resolved before implementation. This is especially significant because cultural resource inventory for the southern part of the project area is also still incomplete. Approving the action before consultation is concluded and before Section 106 inventory is finished in the south violates the spirit of government-to-government consultation and EO 13007. The agency should complete tribal consultation and southern Section 106 inventory and disclose their outcomes before making a final decision.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe EA proposes prescribed broadcast burning on up to 46,073 acres but states that 'exact locations would be determined at a later date with review by resource specialists.' It also states that shaded
The EA proposes prescribed broadcast burning on up to 46,073 acres but states that 'exact locations would be determined at a later date with review by resource specialists.' It also states that shaded fuel breaks range from 285 to 2,289 acres depending on whether other silvicultural treatments occur. These are not minor details; they represent the majority of the project footprint and the primary mechanism for achieving the stated fire-hazard reduction purpose. Deferring location decisions to post-NEPA review means the public has no meaningful opportunity to comment on where burning will occur relative to residences, water sources, sensitive plant communities, or cultural sites. The agency should either fix the burn unit boundaries in the EA or prepare a supplemental analysis once locations are determined, before implementation.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe EA concedes that the project's site index averages 53.2, well below the Black Hills National Forest average of 68.6, and that 11 percent of the project area is unsuitable for timber production.
The EA concedes that the project's site index averages 53.2, well below the Black Hills National Forest average of 68.6, and that 11 percent of the project area is unsuitable for timber production. It then proposes 461 acres of harvest on lands with 'restrictive topography' to make 'previously inaccessible or uneconomical' areas accessible (Table 20), while also authorizing up to 478 acres of harvest on slopes of at least 40 percent. NFMA requires that timber harvests on unsuitable lands be justified by multiple-use objectives, but the EA's rationale for the topographically restricted acres is simply that advanced logging techniques now make harvest 'feasible,' which is an economic justification, not an ecological one. The agency should provide a written multiple-use justification for each category of unsuitable-land harvest that goes beyond cost and access feasibility.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe EA acknowledges that stand age is used as a proxy for Culmination of Mean Annual Increment (CMAI) 'due to limited recent stand inventory data,' and that all stands 120 years or older are assumed t
The EA acknowledges that stand age is used as a proxy for Culmination of Mean Annual Increment (CMAI) 'due to limited recent stand inventory data,' and that all stands 120 years or older are assumed to have reached CMAI. NFMA requires that final removal harvests occur only after CMAI. Using a blanket age proxy instead of actual inventory data for a project authorizing 9,677 acres of commercial harvest, including overstory removal and shelterwood seed cuts, means the agency cannot confirm that it is meeting a statutory requirement. The agency should either conduct updated stand inventory to verify CMAI for stands proposed for final-removal prescriptions or explain in detail why the age proxy is scientifically valid for each prescription type used.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe EA states that non-priority invasive plant species 'could increase to as many as 4,400 acres' under the proposed action, compared to a current documented extent on approximately 2,300 acres.
The EA states that non-priority invasive plant species 'could increase to as many as 4,400 acres' under the proposed action, compared to a current documented extent on approximately 2,300 acres. That is a projected near-doubling of non-priority weed coverage, yet the agency dismisses this impact by asserting that fire hazard reduction benefits would outweigh the harm. No quantitative comparison is provided: the EA does not estimate how many acres of weed infestation a severe wildfire would cause, nor cite a study showing that the specific weed species present respond more to fire than to mechanical disturbance. The agency should provide a quantitative comparison or cite site-specific evidence before concluding that the tradeoff favors the proposed action.
A hole PLAN found in the agency’s own analysis, quote verified against the document
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