Stop logging 1,735 acres of Willamette National Forest plantations

Issues on the record, checked against the decision

• Partially respondedThree northern spotted owl home ranges have proposed treatments that would downgrade suitable habitat, and the EA's own Table 15 shows that MSNO 2803 and 2818 are already below the functional threshol

  Three northern spotted owl home ranges have proposed treatments that would downgrade suitable habitat, and the EA's own Table 15 shows that MSNO 2803 and 2818 are already below the functional thresholds -- MSNO 2803's core area is at 45.9 percent suitable habitat (below the 50 percent threshold) and MSNO 2818's home range is at 31.5 percent suitable habitat (well below the 40 percent threshold). The agency proposes to proceed with treatments that would further reduce suitable habitat in these already-impaired territories, deferring any halt only if surveys detect occupancy that year. The document does not explain how further reducing habitat in territories already below viability thresholds is consistent with the 2023 LAA Biological Opinion's standard against causing jeopardy. The agency should explain how additional impairment of territories already below functional thresholds is consistent with the Biological Opinion, or formally elevate those units to a Level 1 Review before any implementation.

  A hole PLAN found in the agency’s own analysis, quote verified against the document

  “project design features and surveys prior to and during implementation will ensure the territories are not impaired while they are actively occupied by an owl; there will be no direct harm to the species (incidental take).”

  The agency’s own words, Both beneficial and adverse effects · read by the harvest engine, excerpt verified against the document

• Not addressedThe EA notes that the soil disturbance analysis -- including the soil report and slope stability findings -- is located entirely in the project record and not in the EA itself, with the text only refe

  The EA notes that the soil disturbance analysis -- including the soil report and slope stability findings -- is located entirely in the project record and not in the EA itself, with the text only referencing it in Table 20. Yet the document identifies 69 acres of pre-existing detrimental soil conditions across more than 1,700 harvest acres, states that 800 acres of highly erodible, shallow, rocky soils with southerly aspects exist in commercial thinning units, and acknowledges that ground-based equipment is proposed on some of these same acres. NEPA requires that the EA itself contain the hard look at significant issues; placing the soil disturbance analysis exclusively in the project record and outside the public comment document prevents the public from reviewing and commenting on it. The agency should incorporate the soil disturbance and slope stability analysis into the EA, or extend the public comment period after making the full soil report publicly available.

  A hole PLAN found in the agency’s own analysis, quote verified against the document