GMUG forests near decision on South Uncompahgre Plateau vegetation project

Issues on the record, awaiting the decision

• PendingThe EA states that Tribal consultation was initiated in April 2025 and that the GMUG 'has not received feedback at this time' from any of the four consulted tribes (Navajo Nation, Southern Ute Tribe,

  The EA states that Tribal consultation was initiated in April 2025 and that the GMUG 'has not received feedback at this time' from any of the four consulted tribes (Navajo Nation, Southern Ute Tribe, Ute Indian Tribe, and Ute Mountain Ute Tribe) as of the date of the Final EA. The project area spans a landscape with over 1,900 documented cultural resources, approximately 150 of which are eligible for the National Register of Historic Places, and Table 8 documents continuous Indigenous occupation from the Paleoindian period through historic Ute dispossession. Signing a decision while government-to-government consultation remains open and unresolved is inconsistent with the National Historic Preservation Act Section 106 and Forest Service trust responsibilities. The agency should not issue a final decision until all four tribes have had a meaningful opportunity to respond and any identified concerns have been addressed or formally resolved in the record.

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

• PendingThe document states the existing NFS road network in the project area totals approximately 380 miles broken into specific categories, a checkable inventory of roads on the ground.

  The document states the existing NFS road network in the project area totals approximately 380 miles broken into specific categories, a checkable inventory of roads on the ground.

• PendingThe Biological Assessment (BA) was not complete at the time of the Final EA.

  The Biological Assessment (BA) was not complete at the time of the Final EA. The document states: 'The BA is currently being revised based on initial feedback received from the USFWS. Consultation with the USFWS will be completed prior to publication of the Final Decision. Once the USFWS concurs with the determinations made for federally listed threatened, endangered, or proposed (TEP) species, as outlined in the Wildlife, Botany, and Noxious and Invasive Weeds section, concurrence dates will be recorded in the Final Decision Notice.' The EA therefore presents species effect determinations (e.g., 'may affect but is not likely to adversely affect GUSG') without the required USFWS concurrence in hand. A signed FONSI based on an incomplete Section 7 consultation is procedurally premature and may not lawfully authorize ground-disturbing activities that could affect federally listed species. The agency should withhold the decision until USFWS issues formal concurrence on all TEP determinations and should make that concurrence publicly available before the decision is signed.

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

• PendingThe EA authorizes up to 181,400 acres of prescribed burning outside the HFMZ over a 20-year period, yet the fire modeling used to justify the decision is based only on current conditions.

  The EA authorizes up to 181,400 acres of prescribed burning outside the HFMZ over a 20-year period, yet the fire modeling used to justify the decision is based only on current conditions. The document states that 'FlamMap modeling indicates there is currently little potential for active crown fire activity' and that 'less than one percent (or 465 acres of the Project area) would burn at a high to very high intensity under the No Action Alternative.' If the existing fire hazard is already low under current conditions, the EA does not explain why landscape-scale treatments outside the HFMZ are urgently needed now rather than phased over time as conditions change. The agency should provide a quantified analysis of how fire risk changes over the 20-year planning horizon under the No Action Alternative to justify the full scope of the outside-HFMZ prescribed burn program, or narrow the authorization to areas where modeling shows materially elevated risk within a defined near-term window.

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

• PendingThe EA dismisses without detailed analysis a commenter-proposed alternative that would limit silvicultural treatments to the 21,200-acre EIP footprint.

  The EA dismisses without detailed analysis a commenter-proposed alternative that would limit silvicultural treatments to the 21,200-acre EIP footprint. The rationale given is that constraining treatment to the EIP 'would foreclose the Forest Service's ability to respond adaptively.' However, the document also acknowledges that the EIP was created through systematic multi-factor stand selection, field reconnaissance from 2019-2024, and LiDAR analysis, and that it 'identifies areas of priority treatment within the first ten years of implementation.' In other words, the agency already has a well-defined, analytically grounded alternative that addresses the near-term purpose and need. Dismissing it without quantitative comparison of effects violates NEPA's requirement to rigorously explore and objectively evaluate all reasonable alternatives. The agency should analyze the EIP-only alternative in detail, including a comparative effects table, so decision-makers and the public can evaluate the tradeoffs between the full AOO and a more bounded action.

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

• PendingThe EA identifies 12 municipal watersheds within the project area and acknowledges that proposed SUHFER actions are anticipated to occur within them, yet the analysis of effects to drinking water sour

  The EA identifies 12 municipal watersheds within the project area and acknowledges that proposed SUHFER actions are anticipated to occur within them, yet the analysis of effects to drinking water sources is deferred entirely to the implementation checklist phase. The document states that 'a review of land management authorizations and on-the-ground structure delineations would provide guidance and clarify applicable PDFs,' and that 'delineation of watershed resources and features is expected to occur before Project implementation.' One of those watersheds, Naturita Canyon CRA, is explicitly noted as a municipal water supply, though the document concedes 'it is unknown which municipal water supply is provided by the Naturita Canyon CRA.' The agency cannot lawfully find no significant impact to municipal drinking water when it has not yet determined which community's water supply is at stake or what protections apply. The agency should identify each affected municipal water system by name, disclose the specific protections that will apply in each watershed, and complete that analysis before signing the decision.

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

• PendingThe EA proposes up to 8,000 acres of pinyon-juniper woodland treatments for wildlife habitat improvement, including mastication, chipping, pile burning, and broadcast burning, while simultaneously ack

  The EA proposes up to 8,000 acres of pinyon-juniper woodland treatments for wildlife habitat improvement, including mastication, chipping, pile burning, and broadcast burning, while simultaneously acknowledging that the pinyon jay (a species petitioned for ESA listing) has documented habitat within the project area and that 6,521 acres of pinyon-juniper dominant life form are subject to treatment. The document concedes that 'HFMZ activities would have long-term detrimental effects to pinyon-juniper woodlands and nesting sites' for this species. Yet the EA concludes these effects are 'insignificant and discountable' based solely on the absence of confirmed colonies in the project area and a claim that only 'a few surveys have been completed.' The agency cannot reasonably discount long-term habitat loss for a petitioned species on the basis of inadequate survey effort. The agency should complete systematic pinyon jay colony surveys across the full treatment footprint and incorporate results into a revised effects analysis before authorizing pinyon-juniper treatments.

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

• PendingThe EA projects that climate change will render ponderosa pine, Engelmann spruce, subalpine fir, and Douglas-fir habitat 'unsuitable' on the Plateau within decades, citing Worrall and Rehfeldt 2021.

  The EA projects that climate change will render ponderosa pine, Engelmann spruce, subalpine fir, and Douglas-fir habitat 'unsuitable' on the Plateau within decades, citing Worrall and Rehfeldt 2021. The same source projects that pinyon-juniper and Gambel oak 'are expected to persist and expand as climate change progresses.' Yet the Proposed Action directs up to 36,000 acres of silvicultural treatment into ponderosa pine and warm-dry mixed-conifer stands, the ecosystem category the agency's own climate modeling identifies as at highest risk of becoming climatically unsuitable. The EA does not reconcile whether intensive investment in treating stands that may be ecologically unviable within the project's 20-year implementation window represents sound use of public funds or achieves lasting resilience. The agency should directly analyze whether silvicultural treatments in high-vulnerability ponderosa pine stands are likely to achieve the stated desired future condition given projected climate trajectories, or whether resources would be better directed to more climatically suitable ecosystems.

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

• PendingThe EA dismisses an alternative that would prepare a programmatic EIS followed by site-specific EAs, stating that 'the environmental consequences of the Proposed Action would be identical regardless o

  The EA dismisses an alternative that would prepare a programmatic EIS followed by site-specific EAs, stating that 'the environmental consequences of the Proposed Action would be identical regardless of whether they were analyzed in a programmatic EIS or a project-level EA.' This reasoning is circular: the entire point of a programmatic EIS is that it would require the agency to fully disclose and analyze cumulative effects, alternatives, and mitigation at a scale commensurate with the 20-year, 267,300-acre decision before irreversible commitments are made. The EA itself repeatedly defers critical analyses (soil disturbance, municipal watershed protection, tribal feedback, USFWS concurrence) to the implementation phase. That pattern of deferral is precisely the analytical gap that a programmatic EIS is designed to prevent. The agency should prepare an EIS for this project, or at minimum demonstrate how the CBM approach satisfies NEPA's hard-look requirement without an EIS given the acknowledged gaps in the current analysis.

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

• PendingThe EA relies on condition-based management (CBM) to defer site-specific analysis to implementation checklists, yet the document simultaneously claims to have analyzed effects at the EA level.

  The EA relies on condition-based management (CBM) to defer site-specific analysis to implementation checklists, yet the document simultaneously claims to have analyzed effects at the EA level. The Watershed section candidly states that 'the actual activity polygons would be determined based on field reconnaissance and additional GIS analysis. Therefore, cumulative detrimental soil disturbance per activity area is not assessed in this analysis.' This is not a minor gap: the project authorizes up to 50,000 acres of ground-disturbing silvicultural treatments, up to 44 miles of new temporary roads, and hazardous fuels work across 181,400 acres outside the HFMZ, yet the agency cannot assess cumulative soil disturbance because the locations are unknown. NEPA requires that environmental consequences be analyzed before a decision is made, not after. The agency should either constrain the project to the known 21,200-acre EIP footprint where site-specific analysis is possible, or prepare an EIS with full cumulative soil and watershed analysis before authorizing ground-disturbing work across the broader AOO.

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