Mark Twain National Forest approves logging in Blooming Rose project

Issues on the record, checked against the decision

• Partially respondedThe Section 106 review explicitly states that historic properties are present within the Area of Potential Effects and that, without mitigation, they could be adversely affected, yet the FONSI declare

  The Section 106 review explicitly states that historic properties are present within the Area of Potential Effects and that, without mitigation, they could be adversely affected, yet the FONSI declares no significant impacts and authorizes immediate implementation. The EA acknowledges that Section 106 consultation remains ongoing and has not been completed, meaning the agency is signing a FONSI before legally required consultation has concluded. The agency should either complete Section 106 consultation and receive concurrence from Tribes and SHPO before signing, or at minimum extend the decision until all consulting parties have responded and all survey limitations have been resolved.

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

  “Section 106 consultation for the Blooming Rose Proposal remains ongoing and is being conducted in accordance with the processes established in the 2019 Section 106 Programmatic Agreement. Analysis of the anticipated effects of specific activities proposed as well as any letters of comment from consulting parties will be included in the Blooming Rose proposal record.”

  The agency’s own words, National Historic Preservation Act – Section 106 Review · read by the harvest engine, excerpt verified against the document

• RespondedThe document states specific National Forest System roads proposed for decommissioning are currently impassible to passenger vehicles due to being overgrown or damaged.

  The document states specific National Forest System roads proposed for decommissioning are currently impassible to passenger vehicles due to being overgrown or damaged. A volunteer could drive or walk these road segments to confirm whether they are in fact overgrown and impassible as claimed.

  “These roads or parts of these roads are currently not suitable for passenger vehicles due to being overgrown or having resource damage and are impassible. These roads would be closed to public use after NEPA signing.”

  The agency’s own words, Forest Service System Road Decommissioning · read by the harvest engine, excerpt verified against the document

• RespondedThe document claims a specific pond outside the fenced grazing allotment has silted in so much that it has compromised buried delivery piping.

  The document claims a specific pond outside the fenced grazing allotment has silted in so much that it has compromised buried delivery piping. Standing at the pond would show the current sediment level and whether the piping is visibly compromised.

  “This pond has since silted in greatly reducing its holding capacity thus compromising the delivery piping buried underground. Maintenance is required for draining, digging out, and re-piping.”

  The agency’s own words, Pond Maintenance or Construction in Grazing Allotment · read by the harvest engine, excerpt verified against the document

• RespondedThe document asserts that many existing wildlife waterholes across the project have filled with sediment or become clogged with vegetation.

  The document asserts that many existing wildlife waterholes across the project have filled with sediment or become clogged with vegetation. A volunteer could photograph these ponds to confirm sediment buildup or vegetation clogging.

  “Many existing waterholes in the Blooming Rose project have filled in with sediment, and/or are becoming clogged with vegetation. In addition, some of the dams are not working properly and trees are growing on the dam faces themselves, which can result in future dam failure.”

  The agency’s own words, Pond Maintenance for Wildlife · read by the harvest engine, excerpt verified against the document

• RespondedThe document states some pond dams are malfunctioning and have trees growing directly on the dam faces, risking failure.

  The document states some pond dams are malfunctioning and have trees growing directly on the dam faces, risking failure. This is a directly observable physical condition at the dam structures.

  “some of the dams are not working properly and trees are growing on the dam faces themselves, which can result in future dam failure. Maintaining these watering holes provides a diverse habitat for amphibians as well as other wildlife species, including Indiana and Gray bat.”

  The agency’s own words, Pond Maintenance for Wildlife · read by the harvest engine, excerpt verified against the document

• RespondedThe document identifies 59 specific mature stands totaling approximately 796 acres to be designated old growth, implying these stands currently possess characteristics such as large diameter trees, sn

  The document identifies 59 specific mature stands totaling approximately 796 acres to be designated old growth, implying these stands currently possess characteristics such as large diameter trees, snags, and downed logs. A volunteer could visit these stands to check for these old-growth indicators.

  “Fifty-nine mature stands, approximately 796 acres, would be designated old growth in Management Prescriptions 2.1 and 6.3. Acres include a variety of forest types and block sizes to provide a diversity of old growth forest conditions now and in the future at sustainable levels.”

  The agency’s own words, Old Growth Designation · read by the harvest engine, excerpt verified against the document

• RespondedThe document claims 34 specific stands (263 acres) represent dense populations of eastern redcedar, distinct from the more scattered cedar elsewhere in the project area.

  The document claims 34 specific stands (263 acres) represent dense populations of eastern redcedar, distinct from the more scattered cedar elsewhere in the project area. A volunteer could stand in these stands versus other areas to compare cedar density.

  “These targeted stands represent dense populations of cedar; however, cedar is scattered throughout the project and may be cut anywhere within the project area.”

  The agency’s own words, Cedar Removal · read by the harvest engine, excerpt verified against the document

• RespondedThe document characterizes the vegetation cover of the two prescribed burn units differently: Pocket Eddy as primarily open grassland and Trout as closed canopy mixed hardwoods and shortleaf pine.

  The document characterizes the vegetation cover of the two prescribed burn units differently: Pocket Eddy as primarily open grassland and Trout as closed canopy mixed hardwoods and shortleaf pine. A volunteer standing in each unit could confirm the described vegetation type and canopy closure.

  “The Pocket Eddy Rx Burn Unit is approximately 337 acres (comprised primarily of open grassland) and the Trout Rx Burn Unit is approximately 826 acres (comprised of closed canopy mixed hardwoods and short leaf pine).”

  The agency’s own words, Proposed Prescribed Burn Treatment Units · read by the harvest engine, excerpt verified against the document

• RespondedThe document specifies that the fire control lines for the burn units total 8.97 miles, made up mostly of pre-existing roadway and creek/river with only small amounts of newly constructed line.

  The document specifies that the fire control lines for the burn units total 8.97 miles, made up mostly of pre-existing roadway and creek/river with only small amounts of newly constructed line. A volunteer could walk the described perimeter to confirm how much is existing road versus dozer-constructed line.

  “A total of approximately 8.97 miles of perimeter control line will be utilized during the treatment of the two burn units in the Blooming Rose Project Area. The break down is approximately as follows, 2.36 miles of creek/river, 5.03 miles of pre-existing roadway, 1.18 miles of dozer constructed line, 0.04 miles of leaf blower/hand constructed line”

  The agency’s own words, Fire Control Line to be Utilized · read by the harvest engine, excerpt verified against the document

• RespondedThe document asserts that under No Action, 70% of National Forest System lands in the project area are currently in age classes older than 70 years, describing existing stand age as a baseline conditi

  The document asserts that under No Action, 70% of National Forest System lands in the project area are currently in age classes older than 70 years, describing existing stand age as a baseline condition. A volunteer with knowledge of stand age indicators could check whether stands appear to be mature/older forest as claimed.

  “The No Action alternative would retain 70% of National Forest System lands within the project area in older (> 70 years) age classes. The health of dense timber stands would continue to decline and become more susceptible to insects and disease.”

  The agency’s own words, Consideration of No Action (Alternative 1) · read by the harvest engine, excerpt verified against the document

• RespondedThe document states there are approximately 12 miles of non-system roads in the project area that are not open to public vehicles and would be decommissioned.

  The document states there are approximately 12 miles of non-system roads in the project area that are not open to public vehicles and would be decommissioned. A volunteer could locate these routes and confirm their existence and current lack of official designation.

  “There are approximately 12 miles of non-system roads that would be decommissioned to protect forest resources and reduce illegal road use. Non-system road decommission may involve blocking access with earthen berms, boulders, slash piles, restoration of natural drainage features by re-contouring roadbeds”

  The agency’s own words, Non-System Road Decommissioning · read by the harvest engine, excerpt verified against the document

• Partially respondedThe Osage Nation requested an extension to the original consultation deadline of January 16, 2026, and as of April 8, 2026, no letters of comment had been received from any of the three Tribes formall

  The Osage Nation requested an extension to the original consultation deadline of January 16, 2026, and as of April 8, 2026, no letters of comment had been received from any of the three Tribes formally consulted. The public comment period then closed May 29, 2026, and the FONSI was issued in July 2026, all while Tribal responses were still outstanding. The agency should pause the decision, allow adequate time for Tribal responses, and document how Tribal input was considered before issuing a final decision.

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

  “Osage Nation representatives requested an extension to the original consult deadline, January 16th, 2026. No letters of comment have been received as of April 8th, 2026.”

  The agency’s own words, Consultation with Federally Recognized Tribes · read by the harvest engine, excerpt verified against the document

• RespondedThe soils section acknowledges that the cumulative effects model constrains analysis to a single year, even though the project is typically implemented over a ten-year period and involves up to 14.5 m

  The soils section acknowledges that the cumulative effects model constrains analysis to a single year, even though the project is typically implemented over a ten-year period and involves up to 14.5 miles of temporary road construction and over 1,100 acres of regeneration harvests. By compressing all disturbances into one modeled year, the agency produces a worst-case single-year snapshot but never analyzes the actual multi-year cumulative sediment and compaction loading that would occur across overlapping watersheds. The agency should either run multi-year cumulative watershed analysis or explicitly justify why the single-year model is protective given a decade-long implementation schedule.

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

  “The proposed actions are constrained to a single year with this model. This will express the maximum possible effect that could occur and set no limits on the timing of implementation. On the Mark Twain National Forest, projects are typically implemented over the course of 10-year time period and on average only 15% of the proposed silviculture treatments occur on an annual basis throughout the project area”

  The agency’s own words, Soil and Water Prediction Models Used in Blooming Rose · read by the harvest engine, excerpt verified against the document

• Partially respondedThree bat species (Indiana bat, Northern Long-Eared bat, and Tricolored bat) received a 'Likely to Adversely Affect' determination under the Endangered Species Act, yet the EA's FONSI concludes there

  Three bat species (Indiana bat, Northern Long-Eared bat, and Tricolored bat) received a 'Likely to Adversely Affect' determination under the Endangered Species Act, yet the EA's FONSI concludes there are no significant impacts without explaining how adverse effects to three federally endangered species are consistent with a Finding of No Significant Impact. The agency should prepare an Environmental Impact Statement or, at minimum, provide explicit reasoned analysis reconciling the LAA determinations with the FONSI significance thresholds under 40 CFR 1508.27.

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

  “Indiana bat Endangered No LAA See Programmatic BCS; Northern Long Eared bat Endangered No LAA See Programmatic BCS; Tricolored bat Endangered No LAA See Programmatic BCS”

  The agency’s own words, Table 7 · read by the harvest engine, excerpt verified against the document

• Partially respondedThe scoping period ran only 14 days, from April 21 to May 5, 2025, which is far shorter than the 30-day minimum recommended by Council on Environmental Quality guidance for projects of this scale and

  The scoping period ran only 14 days, from April 21 to May 5, 2025, which is far shorter than the 30-day minimum recommended by Council on Environmental Quality guidance for projects of this scale and complexity. Only two comments were received, a result that may reflect inadequate notice rather than lack of public concern. The agency should explain why a 14-day scoping window was sufficient for a 6,774-acre project involving multiple threatened and endangered species, ongoing Section 106 consultation, and over 2,200 acres of commercial harvest, or extend the scoping period and re-engage the public.

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

  “A preliminary scoping period began on April 21st, 2025, and concluded on May 5th, 2025. Interested parties were emailed a copy of the scoping period letter and scoping period package. Two comments were received during this period and were considered by the interdisciplinary team.”

  The agency’s own words, Individuals and Public Involvement · read by the harvest engine, excerpt verified against the document

• Partially respondedThe document states that the Big Piney River scenic segment carries a Visual Quality Objective of Retention or Partial Retention under Management Prescription 6.3, yet the EA provides no stand-level a

  The document states that the Big Piney River scenic segment carries a Visual Quality Objective of Retention or Partial Retention under Management Prescription 6.3, yet the EA provides no stand-level analysis demonstrating that any of the regeneration harvests, salvage units, or temporary road construction within or adjacent to the MP 6.3 corridor actually meet those VQO standards. The agency should provide site-specific VQO compliance analysis for all treatment units visible from the Big Piney River scenic segment before approving harvest activities in or near that corridor.

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

  “In Management Prescription 6.3, for scenic segments, the Forest Plan states, 'design management activities to meet, as a minimum, a Visual Quality Objective of Retention or Partial Retention to maintain current characteristic landscape'”

  The agency’s own words, Scenic Resources · read by the harvest engine, excerpt verified against the document

• Partially respondedThe document states that the area of potential effects includes historic properties that could be adversely affected, yet the heritage section simultaneously declares that proposal activities are 'not

  The document states that the area of potential effects includes historic properties that could be adversely affected, yet the heritage section simultaneously declares that proposal activities are 'not expected to have an impact on heritage resources.' These two statements directly contradict each other with no explanation. The agency should resolve this internal contradiction by completing the full archaeological survey, obtaining SHPO and Tribal concurrence, and issuing a single, consistent effects determination before implementation.

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

  “Proposal activities are not expected to have an impact on heritage resources. Additional analysis can be found in the section titled 'National Historic Preservation Act – Section 106 Review'.”

  The agency’s own words, Heritage · read by the harvest engine, excerpt verified against the document

• Partially respondedThe document acknowledges that some Bender, Poynor, and Viburnum soils are highly erodible at slopes of 15 percent and greater, and that slopes in these series range up to 60 percent, yet no quantitat

  The document acknowledges that some Bender, Poynor, and Viburnum soils are highly erodible at slopes of 15 percent and greater, and that slopes in these series range up to 60 percent, yet no quantitative analysis identifies how many harvest acres fall on slopes above the erodibility threshold or how many acres exceed 35 percent slope where the soils are described as poorly suited for harvest equipment. The agency should provide a slope and soil erodibility overlay for all harvest units and demonstrate that units on high-risk slopes either meet Forest Plan standards or will be excluded from heavy equipment operations.

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

  “Several of these soil series are highly erodible at 15% and greater as stated in the Mark Twain Forest Plan. This will mean implementation standards and guidelines created for highly erodible soils will be necessary.”

  The agency’s own words, Existing Soil Conditions · read by the harvest engine, excerpt verified against the document

• Partially respondedThe carbon and climate analysis cites literature acknowledging that harvest operations release carbon and reduce carbon storage, and that older stands have higher carbon storage, yet the agency conclu

  The carbon and climate analysis cites literature acknowledging that harvest operations release carbon and reduce carbon storage, and that older stands have higher carbon storage, yet the agency concludes that harvesting will increase carbon storage without quantifying the net carbon balance, the magnitude of the release, the time lag to recovery, or the probability of offsetting wildfire emissions under No Action. The agency should provide a quantitative net carbon accounting across the project life, including the release from logging slash, soil respiration, and wood product decay, before relying on carbon benefits to justify the harvest program.

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

  “The proposed harvest operations would result in a release of carbon and reduce carbon storage in the forest both by removing organic matter (trees) and by increasing heterotrophic soil respiration. Logging operations would cause an increase in the amount of down woody debris from logging slash that is left following the removal of merchantable logs.”

  The agency’s own words, Vegetation (Silviculture) · read by the harvest engine, excerpt verified against the document

• Partially respondedThe document proposes decommissioning approximately 2.4 miles of National Forest System Roads and states these roads would be closed to public use after NEPA signing, yet it also states these same roa

  The document proposes decommissioning approximately 2.4 miles of National Forest System Roads and states these roads would be closed to public use after NEPA signing, yet it also states these same roads would be used to facilitate timber harvesting after closure. The EA does not analyze the traffic, sediment, or access impacts of continuing commercial logging use on roads that are simultaneously being closed to the public and eventually decommissioned. The agency should analyze the interim period of logging traffic on roads designated for decommissioning and explain what resource protections will apply during that window.

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

  “Currently, the public does not have access to the entire 2.4 miles of road being decommissioned due to vegetation growing in the roadway. Decommissioning would help ensure that drivers are not using unsafe roads and would return the land back into suitable areas for natural resource production”

  The agency’s own words, Alternative 2 · read by the harvest engine, excerpt verified against the document