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Record closed September 2, 2026
An unpaved national forest road climbing through autumn aspens

Comments closed September 2 · decided

Support prescribed burning across Idaho Panhandle National Forests

Pictured: An unpaved national forest road climbing through autumn aspensMore Than Just Parks
What
The Forest Service wants to use controlled burns to reduce wildfire risk for Idaho Panhandle communities and forests.
Where
Idaho Panhandle National Forests, ID
Decided
Comments closed September 2, 2026. The decision is on file: Final EA with Appendices_IPNF Forestwide Prescribed Fire Project_Sept2026. Open it ↗Date from Forest Service CARA comment page ↗, read October 29, 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.
  • approximately 10,000 acres“The Forest Service anticipates treating approximately 10,000 acres with prescribed fire during a typical implementation year” Proposed Action Open the document ↗
  • up to 30,000 acres in any single year“The decision authorizes implementation of up to 30,000 acres during any individual year should operational capacity and environmental conditions allow.” Proposed Action Open the document ↗
  • 681,220 acres“Backcountry is the second largest MA designation in the Forest Plan, encompassing 681,220 acres.” Geographic Treatment Priority Open the document ↗
  • DecidedSeptember 2, 2026, from Forest Service CARA comment page, the notice text ↗: “requested through 9/2/2026 11:59:59 PM (Pacific Standard Time)”. Read October 29, 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

Unreviewed · Source: Decision document, Final EA with Appendices_IPNF Forestwide Prescribed Fire Project_Sept2026 ↗

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 Water Resources section states that 'no short- or long-term adverse effects to water quality, water yield, municipal watersheds, stream channel stability, riparian function, or aquatic habitat would occur' from this project.

    The Water Resources section states that 'no short- or long-term adverse effects to water quality, water yield, municipal watersheds, stream channel stability, riparian function, or aquatic habitat would occur' from this project.

    Yet the Soils section within the same document acknowledges 'localized increases in erosion potential' and 'small areas of compaction, rutting, or displacement may occur,' and the Fisheries section acknowledges 'localized and temporary increases in sediment yield associated with low- to moderate-intensity prescribed burning, handline construction.' Erosion and sediment yield are water quality effects; they are not a separate topic from what the Water Resources section disclaims. The agency cannot reach a zero-adverse-effect conclusion on water quality while acknowledging sediment pulses and erosion from the same activities in adjacent sections of the same document. The agency should delete the absolute no-adverse-effect claim in the Water Resources section, reconcile it with the admissions in the Soils and Fisheries sections, and provide a quantified analysis of short-term water quality effects at both the 10,000-acre typical and 30,000-acre maximum annual treatment levels.

    A hole PLAN found in the agency’s own analysis

    “Short-term effects may include localized and temporary increases in sediment yield associated with low- to moderate-intensity prescribed burning, handline construction, use of existing roads, or temporary disturbance of upland soils. However, project design features, best management practices, RHCA protections, and implementation coordination and review procedures prior to any activities occurring would minimize sediment yield”

    The agency’s own words, Final EA with Appendices_IPNF Forestwide Prescribed Fire Project_Sept2026 ↗, Fisheries Existing Conditions and Environmental Effects · PLAN’s match, unchecked, an answer in part

  • PLAN’s match, not yet checked by a personThe draft Biological Assessment already determined the action 'may affect and is likely to adversely affect Canada lynx, designated lynx critical habitat, grizzly bear, and whitebark pine.' Under 50 CFR 402.14, formal Section 7 consultation must produce a completed Biological Opinion, including an incidental take statement, before the agency makes an irreversible commitment of resources.

    The draft Biological Assessment already determined the action 'may affect and is likely to adversely affect Canada lynx, designated lynx critical habitat, grizzly bear, and whitebark pine.' Under 50 CFR 402.14, formal Section 7 consultation must produce a completed Biological Opinion, including an incidental take statement, before the agency makes an irreversible commitment of resources.

    The Endangered Species Act section states 'If consultation is not completed before project implementation, consultation pursuant to 50 CFR 402.05(b) will be completed as soon as practicable,' plainly authorizing implementation before a Biological Opinion exists. Emergency consultation procedures under EO 14225 do not substitute for a completed Biological Opinion for species already carrying likely-to-adversely-affect determinations. The agency should not issue a final decision or begin any implementation until formal ESA Section 7 consultation is complete and a Biological Opinion with an incidental take statement is in hand for all three species.

    A hole PLAN found in the agency’s own analysis

    “If consultation is not completed before project implementation, consultation pursuant to 50 CFR 402.05(b) will be completed as soon as practicable. The Forest Service has initiated formal consultation with the USFWS for listed species with "likely to adversely affect" determinations and informal consultation for species with "not likely to adversely affect" determinations.”

    The agency’s own words, Final EA with Appendices_IPNF Forestwide Prescribed Fire Project_Sept2026 ↗, Endangered Species Act · PLAN’s match, unchecked

  • PLAN’s match, not yet checked by a personThe document states 'Pursuant to EADs under IIJA, this project will not be subject to the pre-decisional objection review process (36 CFR 218)' because the Forest Supervisor invoked the Emergency Action Determination.

    The document states 'Pursuant to EADs under IIJA, this project will not be subject to the pre-decisional objection review process (36 CFR 218)' because the Forest Supervisor invoked the Emergency Action Determination.

    The 36 CFR 218 objection process is the only formal mechanism by which members of the public can challenge the adequacy of the agency's environmental analysis before implementation begins. This project covers the entire IPNF administrative boundary with ESA consultation still open, Washington SHPO consultation listed as pending, and no individual treatment units identified for public review. The EAD provision in IIJA was intended for site-specific emergencies, not indefinite forestwide programmatic authorizations. The agency should provide a specific written legal justification for applying the EAD to a programmatic EA of this scope and duration, demonstrate that the statutory criteria are satisfied for the forestwide program rather than individual high-risk parcels, and either restore the pre-decisional objection process or extend the public comment period to provide a meaningful substitute opportunity for review.

    A hole PLAN found in the agency’s own analysis

    “Over 96 percent of the project area falls within the landscape identified by Secretary Rollins, and this project will contribute towards forest resilience, community protection and ingress/egress. Forest Supervisor, Timothy Gilloon, has approved the use of the Forest Health and Hazardous Fuels EAD for the Forestwide Prescribed Fire project on the Idaho Panhandle National Forests.”

    The agency’s own words, Final EA with Appendices_IPNF Forestwide Prescribed Fire Project_Sept2026 ↗, Purpose and Need · PLAN’s match, unchecked, an answer in part

  • PLAN’s match, not yet checked by a personThe project rests on a condition-based management framework in which 'Rather than identifying individual prescribed fire treatment units during project planning, the decision authorizes implementation wherever site-specific conditions satisfy the purpose and need.' All site-specific surveys for sensitive plants, whitebark pine, lynx analysis units, cultural resources, and wetland verification are deferred to post-decision implementation reviews described in Appendix B.

    The project rests on a condition-based management framework in which 'Rather than identifying individual prescribed fire treatment units during project planning, the decision authorizes implementation wherever site-specific conditions satisfy the purpose and need.' All site-specific surveys for sensitive plants, whitebark pine, lynx analysis units, cultural resources, and wetland verification are deferred to post-decision implementation reviews described in Appendix B.

    The public cannot evaluate whether any specific watershed, cultural site, or occupied species habitat will be protected when no treatment units are identified at decision time. NEPA requires that reasonably foreseeable impacts be analyzed before the decision is made, not deferred to post-decision administrative checklists that the public has no right to review or challenge, especially when the pre-decisional objection process has also been eliminated. The agency should conduct site-specific surveys and prepare a site-specific analysis for at least the first year of proposed treatments in each geographic area before issuing a final decision, or prepare an EIS that fully discloses the range of site-specific impacts.

    A hole PLAN found in the agency’s own analysis

    “This implementation review is an administrative verification step used to apply the project within the constraints analyzed in this Environmental Assessment and does not defer or establish Forest Plan compliance after the decision.”

    The agency’s own words, Final EA with Appendices_IPNF Forestwide Prescribed Fire Project_Sept2026 ↗, Federally Listed Species · PLAN’s match, unchecked

  • PLAN’s match, not yet checked by a personThe Agencies and Persons Consulted section lists Washington State Historic Preservation Office as '(pending consultation),' meaning consultation has not been completed.

    The Agencies and Persons Consulted section lists Washington State Historic Preservation Office as '(pending consultation),' meaning consultation has not been completed.

    At the same time, the Cultural Resources section acknowledges 'Many cultural resources within the Project Area remain unevaluated or partially documented due to the large geographic scale of the Proposed Action,' yet the Section 106 review concludes no adverse effect on historic properties. Section 106 of the NHPA requires the agency to afford all required consulting parties, including SHPO, a reasonable opportunity to comment before the final decision. A no-adverse-effect finding cannot be reached with a required consulting party outstanding and a documented backlog of unevaluated cultural resources. The agency should complete Washington SHPO consultation, finish all outstanding cultural resource inventories, and provide consulting tribes the opportunity to review completed inventory results before finalizing the decision.

    A hole PLAN found in the agency’s own analysis

    “The Forest Service conducted cultural resource review and consultation in compliance with Section 106 of the NHPA, as amended, and applicable Programmatic Agreements among the Forest Service, Idaho State Historic Preservation Office (SHPO), Washington SHPO, and consulting tribes.”

    The agency’s own words, Final EA with Appendices_IPNF Forestwide Prescribed Fire Project_Sept2026 ↗, National Historic Preservation Act – Section 106 Review · PLAN’s match, unchecked, an answer in part

Decision document: Final EA with Appendices_IPNF Forestwide Prescribed Fire Project_Sept2026 ↗