Each issue against the decision not yet reviewed

• PLAN found no answer, not yet checked by a personThe ESA consultation for northern spotted owl rests on a 2017 Letter of Concurrence that is now eight years old.

  The ESA consultation for northern spotted owl rests on a 2017 Letter of Concurrence that is now eight years old.

  The document acknowledges that if future surveys find new owl sites the project would be adjusted, but the underlying programmatic biological assessment has not been updated to reflect current owl population data, the 2021 Recovery Plan updates, or the 2023 revised critical habitat rule. The agency cannot simply incorporate by reference an eight-year-old concurrence and call Section 7 satisfied for a 2026 project. The agency should either obtain a current site-specific biological opinion from USFWS or demonstrate explicitly why the 2017 LOC remains adequate under current conditions.

  A hole PLAN found in the agency’s own analysis

• PLAN’s match, not yet checked by a personThe fire behavior analysis compares pre- and post-harvest conditions but relies on LANDFIRE data and post-harvest fuel models drawn from 'nearby, prior timber harvests' rather than site-specific measurements.

  The fire behavior analysis compares pre- and post-harvest conditions but relies on LANDFIRE data and post-harvest fuel models drawn from 'nearby, prior timber harvests' rather than site-specific measurements.

  The EA itself warns that initial fine fuel loadings will increase directly after harvest, yet Table 6 shows fine dead fuel loading dropping from 7.0 to 0.5 tons per acre post-harvest with no explanation of when that reduction occurs or how the pile-burning schedule is guaranteed. The agency should provide a time-stepped fuel analysis showing conditions during the window between harvest completion and pile-burn completion, when fire risk is highest.

  A hole PLAN found in the agency’s own analysis

  “Immediately following commercial thinning harvest, stands will have higher surface fuels from the tops and branches that accumulate on the ground during harvest. This fuel load will be removed when follow up fuel treatments are complete and are expected to be effective at reducing stand level fuels for about 10 years.”

  The agency’s own words, SIGNED FINAL Cala-Wiley DN_FONSI ↗, Both short- and long-term effects · PLAN’s match, unchecked, an answer in part

• PLAN found no answer, not yet checked by a personThe economic analysis uses mill capacity data from 2008 and explicitly states 'there are no updated reports detailing current capacity,' then applies an adjusted figure of 1,000 MMBF without explanation.

  The economic analysis uses mill capacity data from 2008 and explicitly states 'there are no updated reports detailing current capacity,' then applies an adjusted figure of 1,000 MMBF without explanation.

  The net present value of the entire project is only $143,977 on $5.1 million in costs, a benefit-cost ratio of 1.03 that leaves essentially no margin. If the 2008-era capacity assumption overstates current market absorption, the project may be economically negative. The agency should obtain current mill capacity data or justify the 1,000 MMBF proxy before certifying economic viability.

  A hole PLAN found in the agency’s own analysis

• PLAN’s match, not yet checked by a personThe EA states that 122 acres of dispersal habitat will be thinned to no less than 35 percent canopy cover, which by the document's own definition removes that acreage from dispersal habitat classification (which requires 40 percent or more).

  The EA states that 122 acres of dispersal habitat will be thinned to no less than 35 percent canopy cover, which by the document's own definition removes that acreage from dispersal habitat classification (which requires 40 percent or more).

  Six known owl nest sites overlap the project, and Table 9 shows dispersal habitat removal occurring in the home ranges of at least two sites (4404 and SH182, 66 acres each). The document then concludes the action is 'not likely to adversely affect' spotted owls without analyzing how temporary removal of dispersal habitat in occupied home ranges affects owl foraging or survival during the 10-to-15-year recovery period. The agency should provide a site-specific analysis of functional territory impacts during the habitat gap period.

  A hole PLAN found in the agency’s own analysis

  “Commercial thinning harvest will temporarily remove some dispersal habitat. The project is likely to adversely affect the threatened species and may impair territories. However, surveys were 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”

  The agency’s own words, SIGNED FINAL Cala-Wiley DN_FONSI ↗, Both beneficial and adverse effects · PLAN’s match, unchecked, an answer in part

• PLAN found no answer, not yet checked by a personThe riparian reserve thinning rationale states that ACSO Objective 9 is not being met and that thinning is therefore permissible under the NWFP exception.

  The riparian reserve thinning rationale states that ACSO Objective 9 is not being met and that thinning is therefore permissible under the NWFP exception.

  However, the document never presents a baseline measurement showing the current status of Objective 9 or any other ACSO in these specific stands; it simply asserts the desired condition is not present. The NWFP places the burden on the agency to demonstrate that thinning is needed to attain ACSOs, not merely that it would accelerate attainment. The agency should provide stand-scale ACSO assessments showing which objectives are unmet and why commercial thinning, rather than natural succession, is the minimum necessary intervention.

  A hole PLAN found in the agency’s own analysis