Flat Tail logging proposed near Whitepine and Beaver Creek

Issues on the record, awaiting the decision

• PendingThe fire behavior modeling in Table 14 shows a dramatic post-treatment result - 100% surface fire, zero crown fire, zero flame lengths above 4 feet - but the EA never explains whether this modeled out

  The fire behavior modeling in Table 14 shows a dramatic post-treatment result - 100% surface fire, zero crown fire, zero flame lengths above 4 feet - but the EA never explains whether this modeled outcome assumes all 23 units are fully implemented simultaneously or sequentially, or what the fire behavior would be during the multi-year implementation window. The document states short-term effects cover '0 to 10 years' and the most disturbance-intensive activities will take 'about five years,' meaning the landscape will be in a transitional, slash-laden condition for years. The agency should disclose modeled fire behavior during implementation, not only post-treatment, before concluding no significant impact.

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

• PendingThe hydrology section acknowledges that White Pine Creek has an approved TMDL for both sedimentation/siltation and temperature, yet Table 15 shows a 192% increase in average annual sediment leaving th

  The hydrology section acknowledges that White Pine Creek has an approved TMDL for both sedimentation/siltation and temperature, yet Table 15 shows a 192% increase in average annual sediment leaving the buffer at the Middle Fork of Set Creek crossing and a 236% increase at the West Fork of Larch Creek crossing during implementation. The EA dismisses these increases by saying the model 'does not consider road upgrades' and the sediment is 'unlikely' to reach White Pine Creek, but offers no quantitative demonstration that these sediment loads stay below TMDL thresholds. The agency should provide a TMDL consistency analysis with actual load numbers before signing a FONSI.

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

• PendingThe noxious weeds section rates both the likelihood of weed spread and the consequence of establishment as 'Moderate,' yielding a 'Moderate' overall risk, and acknowledges that approximately 626 acres

  The noxious weeds section rates both the likelihood of weed spread and the consequence of establishment as 'Moderate,' yielding a 'Moderate' overall risk, and acknowledges that approximately 626 acres of regeneration harvest will remove the most overstory canopy and create the greatest solar insolation for weed establishment. Yet Table 17 offers no quantitative post-treatment monitoring commitment - only a general statement to 'monitor the area for at least 3 consecutive years.' The design features require herbicide treatment of haul routes but contain no requirement to survey regeneration units for new infestations before declaring the project complete. The agency should require documented pre- and post-treatment weed surveys in all regeneration units and bind the purchaser to treatment if new infestations are detected within a defined timeframe.

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

• PendingThe scenery section discloses in Table 19 that 20 of the project's harvest units currently do not meet the Scenic Integrity Objective of 'High' as seen from identified viewpoints, meaning the baseline

  The scenery section discloses in Table 19 that 20 of the project's harvest units currently do not meet the Scenic Integrity Objective of 'High' as seen from identified viewpoints, meaning the baseline is already degraded. The EA then proposes regeneration harvest - including three openings over 40 acres - in units that are visible from Highway 200 and the Big Beaver Creek and White Pine Creek Roads, and concludes only that effects 'may be noticeable' and will recover in the 'mid and long-term.' No quantitative visual contrast rating or simulation is provided to demonstrate that post-harvest conditions will remain subordinate to scenic character as required under the SIO 'High' standard. The agency should provide visual simulations or contrast ratings for the units visible from concern-level viewpoints before concluding the project meets Forest Plan scenic standards.

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

• PendingThe document asserts that Road 14620B is currently not driveable, a condition anyone standing at the road could verify by attempting to drive or walk it before any reconstruction occurs.

  The document asserts that Road 14620B is currently not driveable, a condition anyone standing at the road could verify by attempting to drive or walk it before any reconstruction occurs.

• PendingThe document claims westslope cutthroat trout are absent from all project area streams except along the boundary via Big Beaver Creek and White Pine Creek, attributing this to sub-surface flow during

  The document claims westslope cutthroat trout are absent from all project area streams except along the boundary via Big Beaver Creek and White Pine Creek, attributing this to sub-surface flow during dry seasons, a claim a volunteer could check by observing water presence and fish in the named streams.

• PendingThe document states bull trout may be present in the project area or downstream in Beaver Creek at certain times but that no spawning occurs there, a claim checkable through direct observation of redd

  The document states bull trout may be present in the project area or downstream in Beaver Creek at certain times but that no spawning occurs there, a claim checkable through direct observation of redds or spawning fish.

• PendingThe document states the two fish-bearing stream crossings on the haul route have paved approaches, a physical condition of the road surface that a volunteer could photograph directly.

  The document states the two fish-bearing stream crossings on the haul route have paved approaches, a physical condition of the road surface that a volunteer could photograph directly.

• PendingThe document asserts that no archeological sites or other cultural resources were found anywhere within the project boundary during the District Archeologist's review, a finding that could be contradi

  The document asserts that no archeological sites or other cultural resources were found anywhere within the project boundary during the District Archeologist's review, a finding that could be contradicted by locating any cultural resource on the ground.

• PendingThe document lists specific noxious weed species identified from field surveys along roads in the project area, a claim directly checkable by walking the roadsides and photographing plants.

  The document lists specific noxious weed species identified from field surveys along roads in the project area, a claim directly checkable by walking the roadsides and photographing plants.