Comments closed August 20 · decided
Station Butte logging plan nears final approval in Willamette National Forest
U.S. Forest Service · Willamette National Forest, Middle Fork Ranger District
- What
- The Forest Service is close to approving commercial thinning across nearly 4,000 acres of the Willamette National Forest.
- Where
- Willamette National Forest, Middle Fork Ranger District, OR
- How much
- Only people or organizations who submitted written comments during an earlier public participation window are eligible to file a formal objection.
- Decided
- Comments closed August 20, 2026. The decision is on file: Station Butte Final FONSI and Decision Notice, September 2026. Open it ↗Date from Forest Service legal notice in Register-Guard ↗, read August 15, 2026.
Where these four lines come from
- WhatOur plain-English read of the Forest Service project page ↗. Check it against the agency’s own words under Case.
- WhereThe places and states the project page names, as PLAN read them.
- How muchThe first sentence of our What’s at risk read of the notice; the whole read is under Case.
- DecidedAugust 20, 2026, from Forest Service legal notice in Register-Guard, published July 6, 2026, plus 45 days under 36 CFR 218.6 ↗. Read August 15, 2026. The decision document is the one on file in PLAN’s record.
- Read from PLAN’s record November 9, 2026.
What the proposal said, and what the decision did
Riparian Reserve acres commercially thinned
How would vegetation management impact Riparian Reserve vegetation condition in the project area? ↗ and Activities Approved ↗
Proposed
about 1,058 acresDecided
about 1,058 acres
Unreviewed · Source: Decision notice, Station Butte Final FONSI and Decision Notice, September 2026 ↗
Did the agency answer?
PLAN found 10 issues in the agency’s analysis.
Each issue against the decision, unreviewed
PLAN’s match, not yet checked by a personThe EA proposes harvest operations adjacent to six streams listed under the Clean Water Act as impaired for year-round temperature — Andy Creek, North Fork Winberry Creek, South Fork Winberry Creek, Winberry Creek, Timber Creek, and an unnamed tributary to Fall Creek — yet acknowledges that the Willamette Basin Temperature TMDL was invalidated by litigation in 2018 and that the Forest Service will not submit a new TMDL implementation plan until November 2026, after any decision on this project (Clean Water Act section).
The EA proposes harvest operations adjacent to six streams listed under the Clean Water Act as impaired for year-round temperature — Andy Creek, North Fork Winberry Creek, South Fork Winberry Creek, Winberry Creek, Timber Creek, and an unnamed tributary to Fall Creek — yet acknowledges that the Willamette Basin Temperature TMDL was invalidated by litigation in 2018 and that the Forest Service will not submit a new TMDL implementation plan until November 2026, after any decision on this project (Clean Water Act section).
The EA claims compliance with current CWA guidance while admitting the governing framework for these specific listed waters is not yet in place. Approving a FONSI for 3,998 acres of harvest adjacent to 303(d)-listed waters without a valid compliance mechanism is a legal gap, not an analytical one. The agency should delay the decision until the TMDL implementation plan is submitted and approved, or prepare an EIS that directly demonstrates CWA compliance for activities adjacent to each temperature-impaired waterbody.
A hole PLAN found in the agency’s own analysis
“These impacts are all expected to be short-term and will not exceed water quality thresholds or threaten the viability of any species nor their habitat.”
The agency’s own words, Station Butte Final FONSI and Decision Notice, September 2026 ↗, Both short- and long-term effects · PLAN’s match, unchecked, an answer in part
PLAN’s match, not yet checked by a personThe EA establishes that instream large wood in both sub-watersheds already falls below the Forest Plan's 80-pieces-per-mile target and that both are rated as functioning at risk due to insufficient large wood recruitment (large wood recruitment section, Table 20).
The EA establishes that instream large wood in both sub-watersheds already falls below the Forest Plan's 80-pieces-per-mile target and that both are rated as functioning at risk due to insufficient large wood recruitment (large wood recruitment section, Table 20).
The proposed riparian thinning would then reduce wood recruitment in affected reaches by approximately 30 percent for several decades. The EA does not analyze what a further 30 percent reduction does to watershed condition ratings that are already below threshold, does not model whether ACS Objective compliance can be maintained at post-thinning recruitment levels, and does not compare the no-harvest buffer widths proposed here against a higher-retention alternative. The agency should quantify the combined effect of this additional reduction on already-deficient large wood levels and demonstrate that the proposed action is consistent with ACS Objectives for each affected reach, or prepare an EIS.
A hole PLAN found in the agency’s own analysis
“A short-term reduction of large wood available for recruitment for instream habitat and an increase in sediment delivery to stream channels are also expected. However, stream buffers will protect most of the trees that provide shade or may fall into streams and minimize harvest generated sediment from entering the stream.”
The agency’s own words, Station Butte Final FONSI and Decision Notice, September 2026 ↗, Both short- and long-term effects · PLAN’s match, unchecked, an answer in part
PLAN’s match, not yet checked by a personThe EA's own watershed condition analysis states that road densities in both sub-watersheds exceed the 3.5-mile-per-square-mile threshold associated with elevated stream sedimentation and that water quality functions are impaired in the Andy Creek-Fall Creek watershed (Watershed Condition subsection of the sedimentation section).
The EA's own watershed condition analysis states that road densities in both sub-watersheds exceed the 3.5-mile-per-square-mile threshold associated with elevated stream sedimentation and that water quality functions are impaired in the Andy Creek-Fall Creek watershed (Watershed Condition subsection of the sedimentation section).
The proposed action adds 157 miles of maintained and reconstructed haul routes plus 6.5 miles of new temporary roads to these already-impaired systems. Comment Response #5 explicitly declines to evaluate a minimum road system alternative, characterizing it as outside the scope of the project. The agency cannot rationally certify no significant impact on sediment-impaired watersheds while refusing to analyze whether road use intensity is consistent with restoring rather than maintaining those impaired conditions. The agency should analyze what level of road use and maintenance is compatible with improving watershed condition ratings, or prepare an EIS.
A hole PLAN found in the agency’s own analysis
“Additionally, proven best management practices for minimizing timber haul related sediment transport to streams will be implemented (project design features) that reduce potential short-term sediment impacts.”
The agency’s own words, Station Butte Final FONSI and Decision Notice, September 2026 ↗, Both short- and long-term effects · PLAN’s match, unchecked, an answer in part
PLAN’s match, not yet checked by a personThe EA's summary conclusion for fire effects states that commercial thinning has minimal effect on fire behavior in stands under the modeled weather scenario (fire behavior section).
The EA's summary conclusion for fire effects states that commercial thinning has minimal effect on fire behavior in stands under the modeled weather scenario (fire behavior section).
Table 10 directly contradicts this: the percentage of the project area with rate of spread in the 5-to-20 chains-per-hour category increases more than fourfold post-treatment, from 5 percent to 22 percent, while the slowest category (0-to-2 chains per hour) drops from 54 percent to 21 percent. The EA acknowledges the increase but dismisses it as occurring at lower levels without explaining why a fourfold increase in the intermediate speed category — the range most relevant to suppression decision-making — is not a meaningful change. The internal conflict between the data in Table 10 and the minimal-effect conclusion is unreasoned. The agency should reconcile this contradiction directly, revise the fire behavior conclusion if the data do not support it, and extend the analysis to a range of weather scenarios.
A hole PLAN found in the agency’s own analysis
“In the short-term, should wildfire burn into the treated stands, we expect to see higher flame lengths and a faster rate of spread. However, these increases are limited to lower levels of fire behavior and there is little, if any, change in crown fire behavior expected.”
The agency’s own words, Station Butte Final FONSI and Decision Notice, September 2026 ↗, Both short- and long-term effects · PLAN’s match, unchecked
PLAN’s match, not yet checked by a personThe EA identifies 33 northern spotted owl home ranges overlapping the project area and acknowledges that nearly all of them rest on survey data up to 30 years old (NSO section).
The EA identifies 33 northern spotted owl home ranges overlapping the project area and acknowledges that nearly all of them rest on survey data up to 30 years old (NSO section).
The entire effects analysis — which territories are occupied, whether habitat impairment thresholds are exceeded, whether incidental take will occur — is built on 1990s occupancy data even though the Bedrock Fire in 2023 substantially altered habitat within portions of the project area. Protocol surveys are deferred to pre-sale implementation, after the NEPA decision is made. A decision about whether to impair spotted owl territories cannot rationally be based on occupancy status that predates a 29,000-acre wildfire and 30 years of habitat change. The agency should conduct current occupancy surveys and incorporate the results before issuing a decision, or explain in detail why 1990s data is adequate to evaluate ESA compliance under present conditions.
A hole PLAN found in the agency’s own analysis
“surveys will be conducted in compliance with the Endangered Species Act consultation requirements to ensure that 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, Station Butte Final FONSI and Decision Notice, September 2026 ↗, Both beneficial and adverse effects · PLAN’s match, unchecked, an answer in part
PLAN’s match, not yet checked by a personAlternative B — thinning to maintain higher canopy closure — was designed specifically to reduce northern spotted owl habitat impacts.
Alternative B — thinning to maintain higher canopy closure — was designed specifically to reduce northern spotted owl habitat impacts.
Comment Response #3 confirms this alternative was eliminated from detailed study without any analysis of its effects on fire behavior, the second primary justification for the proposed action. The EA devotes a full analytical section to fire behavior and presents fire risk reduction as a core ecological rationale, yet the only alternative varying canopy retention was dismissed before its fire consequences were examined. An alternative that differs from the proposed action on both owl habitat and post-harvest canopy density — the two variables most directly linked to the EA's own fire behavior model inputs — cannot be rationally eliminated without comparing its fire outcomes to the proposed action. The agency should analyze Alternative B with fire behavior modeling and present that comparison in the EA, or document why such analysis is infeasible.
A hole PLAN found in the agency’s own analysis
“The alternatives proposed completing commercial thinning harvest activities without constructing temporary roads, or while leaving higher rates of canopy closure after treatment to minimize effects to northern spotted owl and deadwood habitat. These alternatives were not studied in detail because they were not economically feasible or would not meet the purpose and need of the project.”
The agency’s own words, Station Butte Final FONSI and Decision Notice, September 2026 ↗, Other Alternatives Considered · PLAN’s match, unchecked, an answer in part
PLAN found no answer, not yet checked by a personThe EA waives all cumulative effects analysis by citing April 2026 USDA NEPA regulations that make such analysis permissive rather than required (Comment Response #20).
The EA waives all cumulative effects analysis by citing April 2026 USDA NEPA regulations that make such analysis permissive rather than required (Comment Response #20).
This waiver applies despite: the Diamond Timber Sale actively thinning 610 acres in 7 NSO territories that overlap this project; the Fuji Thin treating 596 acres in the project area; post-Bedrock Fire sedimentation still ongoing in the Andy Creek-Fall Creek sub-watershed; and the presence of ESA-listed Chinook salmon, for which the EA itself makes a May-Affect-Likely-to-Adversely-Affect determination. The regulations permit cumulative analysis; they do not prohibit it. For a project with listed species, 303(d)-listed streams, and multiple concurrent activities in the same watershed, issuing a FONSI without any evaluation of additive effects is a reasoned-basis gap. The agency should analyze, at minimum, the additive effects on NSO territories of this project plus the Diamond Timber Sale, and on sedimentation of this project plus ongoing post-fire inputs.
A hole PLAN found in the agency’s own analysis
PLAN’s match, not yet checked by a personThe EA acknowledges that the Winberry and Andy Creek-Fall Creek sub-watersheds rank as the top two of 72 sub-watersheds on the Forest for invasive weed site density, and then admits that complete understory type conversion is likely in at least one of the 165 proposed harvest stands (weeds section, Table 18).
The EA acknowledges that the Winberry and Andy Creek-Fall Creek sub-watersheds rank as the top two of 72 sub-watersheds on the Forest for invasive weed site density, and then admits that complete understory type conversion is likely in at least one of the 165 proposed harvest stands (weeds section, Table 18).
The agency's only response to this admitted likely conversion is reliance on PDFs. No alternative was carried forward to reduce disturbance footprint specifically in these two highest-ranked invasive watersheds, and Alternative A (no temporary roads) was eliminated without analyzing its weed-spread implications. An EA that acknowledges likely understory monoculture conversion in the Forest's two worst invasive watersheds, then offers only best-practice design features as mitigation, without analyzing a reduced-footprint alternative, does not take a hard look at this resource impact. The agency should analyze a reduced-disturbance alternative for its effect on invasive spread in these sub-watersheds, or explain why PDFs alone are adequate.
A hole PLAN found in the agency’s own analysis
“Invasive botanical species are prevalent in these watersheds and will spread overtime regardless of the project. However, as a result of commercial thinning harvest activities, the rate of spread will increase and, in some cases, may dominate the understory of stands over time. The project includes a number of project design features that will help limit the spread of these invasive species.”
The agency’s own words, Station Butte Final FONSI and Decision Notice, September 2026 ↗, Both beneficial and adverse effects · PLAN’s match, unchecked, an answer in part
PLAN’s match, not yet checked by a personThe EA computes an upper-bound carbon removal estimate using ForCaMF model data calibrated to 1990-2011 intensive harvest on the Willamette NF, then states that the per-acre figures derived from that data are more representative of clearcut-era harvest than of the variable density thinning proposed here (carbon section).
The EA computes an upper-bound carbon removal estimate using ForCaMF model data calibrated to 1990-2011 intensive harvest on the Willamette NF, then states that the per-acre figures derived from that data are more representative of clearcut-era harvest than of the variable density thinning proposed here (carbon section).
The agency presents this acknowledged overestimate as its only quantitative carbon figure — 171,914 Mg removed — without providing a thinning-specific estimate or even a credible range. NEPA requires disclosure of environmental impacts; an EA that identifies a single central estimate for a major resource while simultaneously acknowledging the estimate does not apply to the proposed action has not disclosed the actual impact. The agency should calculate carbon removal using per-acre figures derived from variable density thinning studies of comparable age and density classes, or explain why no such data exist and what the range of uncertainty is.
A hole PLAN found in the agency’s own analysis
“The modeling used likely overestimates carbon loss per area as it does not account for skips or buffers and assumes harvest will result in reduced stand growth. However, thinning will increase growth of remaining trees, sequestering carbon, and studies have found limited difference in carbon stocks between thinned and unthinned stands after several decades.”
The agency’s own words, Station Butte Final FONSI and Decision Notice, September 2026 ↗, Both beneficial and adverse effects · PLAN’s match, unchecked
PLAN’s match, not yet checked by a personThe EA's economic analysis claims the proposed action would contribute 7.5 percent of local mill capacity and supports this with a baseline mill capacity figure of 1,400 MMBF drawn from 2008 processing data (economics section, Table 7).
The EA's economic analysis claims the proposed action would contribute 7.5 percent of local mill capacity and supports this with a baseline mill capacity figure of 1,400 MMBF drawn from 2008 processing data (economics section, Table 7).
The EA then adjusts this to 1,000 MMBF without citing any source, because the agency acknowledges there are no current capacity reports. Table 6 shows that wood products manufacturing employment in both counties declined from 2015 to 2025, suggesting the industry has contracted since 2008. A contribution-to-capacity metric built on a 17-year-old baseline that the agency substitutes with an uncited assumption does not provide a rational basis for the economic purpose-and-need claim. The agency should use current mill capacity data from a citable source, or acknowledge that the contribution-to-capacity figure cannot be reliably calculated and remove it as a decision-support metric.
A hole PLAN found in the agency’s own analysis
“Mills in these Counties have the capacity to process about 1,000 MMBF of timber, which are currently used at about 68% of their capacity (according to 2008 harvest rates).”
The agency’s own words, Station Butte Final FONSI and Decision Notice, September 2026 ↗, Potentially Affected Environment · PLAN’s match, unchecked, an answer in part
Decision notice: Station Butte Final FONSI and Decision Notice, September 2026 ↗
PLAN's read: high threat
The Forest Service is close to approving commercial thinning across nearly 4,000 acres of the Willamette National Forest.
What’s at risk
If this goes through
Our plain-English read of the official notice ↗. Check it against the agency’s own words below.
The agency’s own analysis
What the notice says, and what it leaves out
The window has closed; the record of what was missing stays.
The agency says
“The Willamette National Forest will complete a TMDL implementation plan by November 2026.”
The EA proposes harvest operations adjacent to six streams listed under the Clean Water Act as impaired for year-round temperature — Andy Creek, North Fork Winberry Creek, South Fork Winberry Creek, Winberry Creek, Timber Creek, and an unnamed tributary to Fall Creek — yet acknowledges that the Willamette Basin Temperature TMDL was invalidated by litigation in 2018 and that the Forest Service will not submit a new TMDL implementation plan until November 2026, after any decision on this project (Clean Water Act section).
The agency says
“Wood levels in both Andy Creek-Fall Creek and Winberry Creek sub-watersheds fall below this level and are rated as functioning at risk”
The EA establishes that instream large wood in both sub-watersheds already falls below the Forest Plan's 80-pieces-per-mile target and that both are rated as functioning at risk due to insufficient large wood recruitment (large wood recruitment section, Table 20).
The agency says
“road densities in the Andy Creek-Fall Creek and Winberry Creek sub-watersheds are high, exceeding levels commonly associated with elevated stream sedimentation (more than 3.5 miles of road per square mile)”
The EA's own watershed condition analysis states that road densities in both sub-watersheds exceed the 3.5-mile-per-square-mile threshold associated with elevated stream sedimentation and that water quality functions are impaired in the Andy Creek-Fall Creek watershed (Watershed Condition subsection of the sedimentation section).
How would commercial thinning harvest influence fire behavior in stands? ↗
The agency says
“commercial thinning harvest would have minimal effect on fire behavior in stands within the project area, under the weather conditions that were modeled”
The EA's summary conclusion for fire effects states that commercial thinning has minimal effect on fire behavior in stands under the modeled weather scenario (fire behavior section).
The agency says
“Nearly all these sites are based on survey results from the 1990s.”
The EA identifies 33 northern spotted owl home ranges overlapping the project area and acknowledges that nearly all of them rest on survey data up to 30 years old (NSO section).
The agency says
“This alternative was eliminated from detailed study, including study of its effects on fuels and fire”
Alternative B — thinning to maintain higher canopy closure — was designed specifically to reduce northern spotted owl habitat impacts.
The agency says
“Under this rule there is no requirement to consider cumulative impacts.”
The EA waives all cumulative effects analysis by citing April 2026 USDA NEPA regulations that make such analysis permissive rather than required (Comment Response #20).
How might commercial harvest result in the spread of weeds? ↗
The agency says
“complete conversion of the understory is likely in one or more stands of the proposed 165 stands within the project area”
The EA acknowledges that the Winberry and Andy Creek-Fall Creek sub-watersheds rank as the top two of 72 sub-watersheds on the Forest for invasive weed site density, and then admits that complete understory type conversion is likely in at least one of the 165 proposed harvest stands (weeds section, Table 18).
What impact would commercial thinning harvest have on biogenic carbon stores? ↗
The agency says
“the per acre estimates used above are more representative of a more intensive harvest than the thinning planned in this project”
The EA computes an upper-bound carbon removal estimate using ForCaMF model data calibrated to 1990-2011 intensive harvest on the Willamette NF, then states that the per-acre figures derived from that data are more representative of clearcut-era harvest than of the variable density thinning proposed here (carbon section).
How would timber sold from commercial thinning harvest contribute to the local economy? ↗
The agency says
“using processing capacity figures for 2008 (Gale et al. 2012); there are no updated reports detailing current capacity”
The EA's economic analysis claims the proposed action would contribute 7.5 percent of local mill capacity and supports this with a baseline mill capacity figure of 1,400 MMBF drawn from 2008 processing data (economics section, Table 7).
In the agency’s own words
Project to address the need for vegetation management to increase stand growth and diversity and support the local economy. Proposed action includes commercial thinning harvest and restoration activities.
The groups on this fight
4 groups predicted likely to care in Oregon
Predicted likely to care is a guess from the group's sourced work in Oregon, with no link to this decision. Give straight to them; nothing routes through us.
- Cascadia Wildlands
Predicted likely to care · a guess
Western Oregon O&C Lands, Oregon: Serial litigant against western Oregon BLM logging, from the 2016 management plan challenge to the current round of timber sale suits.
- Crag Law Center
Predicted likely to care · a guess
Western Oregon O&C Lands, Oregon: Counsel of record for the conservation groups fighting BLM logging across the O&C forests.
- Oregon Natural Desert Association
Predicted likely to care · a guess
McDermitt Caldera, Oregon: Anchors the McDermitt Caldera Coalition on the Oregon side and fought the BLM's December 2025 approval of the Jindalee/HiTech lithium exploration project through the permitting process.
- Oregon Wild
Predicted likely to care · a guess
Western Oregon O&C Lands, Oregon: Its attorneys, with Cascadia Wildlands and Crag Law Center, represent the groups challenging BLM's Blue and Gold old-growth logging project in the Coast Range.
Every group above is on STAND for Public Lands, with its court record, its filings and who backs it.
Who signs it
PLAN hasn’t read a signer into its record for this fight. The decision on file carries the signature: Station Butte Final FONSI and Decision Notice, September 2026 ↗.
The ground
The window has closed, so there’s no watch to set on it here.
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In court on this ground
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Who holds the vote
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