Comments closed September 25
Mt. Baker geothermal leasing nears Forest Service consent decision
U.S. Forest Service · Mt. Baker Ranger District, WA
- What
- The Forest Service is close to approving geothermal leasing rights around Mt. Baker on federal land.
- Where
- Mt. Baker Ranger District, WA
- How much
- Only those who submitted written comments during the earlier public participation window may file an objection now.
- Decided
- Comments closed September 25, 2026. No decision document is on file yet.Date from Forest Service legal notice in The Everett Herald and The Bellingham Herald ↗, read September 26, 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.
- How muchThe first sentence of our What’s at risk read of the notice; the whole read is under Case.
- DecidedSeptember 25, 2026, from Forest Service legal notice in The Everett Herald and The Bellingham Herald, published August 11, 2026, plus 45 days under 36 CFR 218.6 ↗. Read September 26, 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
No figure from the proposal has been checked against the decision on this fight yet. What the record does hold is the issues ledger below.
No decision document is on PLAN’s record for this fight yet. When the agency’s decision lands, what it answered goes here.
Affects public lands
The Forest Service is close to approving geothermal leasing rights around Mt. Baker on federal land.
What’s at risk
If this goes through
Our plain-English read of the official notice ↗. Check it against the agency’s own words below.
The agency’s case, tested
What the agency argues, and whether its own record backs it
- 4
- Hold up
- 2
- Not fully backed
- 3
- Never analyzed
The Forest Service proposes to consent to the BLM offering 60,097 acres of national forest land around Mount Baker for geothermal leasing, subject to stipulations. It says consent itself has no environmental effects because it authorizes no ground disturbance, and any exploration or development would get its own NEPA review.
“The purpose of this project is for the USFS to consider whether to make 60,097 acres of nominated parcels of NFS lands available for geothermal leasing by the BLM.”
Purpose and Need
EffectsNot fully backedThe Appendix C stipulations, applied through later site-specific review, will let future projects reduce or avoid significant environmental impacts.
The agency's strongest support is that Appendix C ties each stipulation to plan guidance, and the Waivers, Exceptions, and Modifications section says a waiver may not be approved unless the factors behind a stipulation have changed enough or the operations wouldn't cause unacceptable impacts. Still, the development scenario section says the magnitude and extent of impacts can't be predicted, the document never reports acres under no surface occupancy, and Appendix D says the BLM, not the Forest Service, decides waivers of no surface occupancy and timing stipulations. No analysis shows how much protection will remain once leases are issued.
The agency’s words, the record and the law +Hide the words
The agency says
“Analysis indicates that, by following the guidance in the Land and Resource Management Plan (LRMP) and other related documents and regulations to determine the stipulations included in EA Appendix C, analysis of future proposals will be able to reduce or avoid significant environmental impacts.”
Appendix D: Response to Comments
Elsewhere in the same document
“Stipulations associated with No Surface Occupancy (NSO) and/or Timing Limitation (TL) can be waived or modified based on approval from the BLM.”
Appendix D: Response to Comments
“The USFS does not have the ability to make NSO areas exempt from waivers or modifications; all such applications would be evaluated at the time they are received.”
Appendix D: Response to Comments
The law
“Resource plans and permits, contracts, and other instruments for the use and occupancy of National Forest System lands shall be consistent with the land management plans.” National Forest Management Act, 16 U.S.C. 1604(i) ↗
EffectsNot fully backedControlled surface use, plus no surface occupancy only in modeled old growth, adequately protects late-successional reserves; guidance doesn't call for no surface occupancy there.
The agency's strongest support is stipulation MBS-WLD-02. It requires any applicant to submit a plan meeting late-successional reserve objectives through special design, mitigation or relocation. It bars surface occupancy if that plan isn't approved, and it requires development to be neutral or beneficial to late-successional habitat. MBS-BOT-01 adds no surface occupancy for old growth. Still, reserve land covers most of the parcels (the largest Table 2 row alone is 39,720 acres). The document doesn't say how many acres the old growth model will cover, and Appendix D doesn't answer the stand-age figures commenters cited.
The agency’s words and the law +Hide the words
The agency says
“Our LRMP, the 2008 PEIS, the NWFP, and other regulatory guidance documents used in this analysis do not provide for a stipulation of NSO in LSR and they do not define all LSR management areas as old-growth; old-growth will be defined by the OGSI-200 model.”
Appendix D: Response to Comments
The law
“Resource plans and permits, contracts, and other instruments for the use and occupancy of National Forest System lands shall be consistent with the land management plans.” National Forest Management Act, 16 U.S.C. 1604(i) ↗
What the document never analyzes
Not analyzedVolcanic and geologic hazards at Mount Baker
The parcels surround Mount Baker, a 10,778-foot peak with permanent glaciers, and the development scenario includes wells, a power plant and transmission lines, but hazards to that infrastructure are never discussed.
Searched all 58 pages for ‘volcanic’, ‘volcano’, ‘lahar’, ‘eruption’. None appear.
Not analyzedWildfire risk from development
The parcels are forest of cedar, Douglas-fir, true firs and hemlock, and the development scenario includes site clearing, drilling and transmission lines, yet fire risk is never addressed.
Searched all 58 pages for ‘wildfire’, ‘fire risk’, ‘ignition’. None appear.
Not analyzedPublic revenue from leasing
The document cites national energy goals and says parcels would be offered for competitive bid, but never estimates lease or royalty income to the public or local counties.
Searched all 58 pages for ‘royalty’, ‘royalties’, ‘lease revenue’, ‘bonus bid’. None appear.
Where its own record backs the agency
AlternativesNo issue justified analyzing any action alternative beyond leasing, leasing with stipulations, or denial.Why it holds +
The agency reasons that without a site-specific proposal, effects are speculative, so the real choices are to lease, lease with stipulations, or deny. Appendix D answers each option commenters raised. Roadless areas already bar new roads under the Roadless Rule, guidance doesn't provide for no surface occupancy across all late-successional reserves, and surface development can still occur outside no surface occupancy areas. Appendix D also explains that the change from 2015 to 2025 came from more tribal consultation and riparian reserves remapped with new data. Those reasons can be disputed, but the document gives them.
The agency says
“Therefore, no issues were identified that would provide a clear reason to develop other action alternatives than to lease, lease with stipulations, or to deny leasing the nominated parcels.”
Substantive Issues Identified for Analysis
Its own record backs it
“A commenter thinks that roadless areas should be NSO instead of CSU, especially roadless areas in Tier 1 Key Watersheds which allow no new roads per the NWFP.”
Appendix D: Response to Comments
EffectsConsenting to lease causes no environmental effects because it authorizes no ground disturbance, and later NEPA review must come before any exploration or development.Why it holds +
The Introduction says the decision only lets the BLM offer parcels for competitive bid, and the Environmental Impacts section says effects would come only with later exploration or development after site-specific review. Nothing in the document shows consent itself disturbs land. Whether the protections set now will hold once leases exist is a separate question, tested below.
The agency says
“The ‘action’ of consenting to lease has no environmental impact on any resource because it does not include any ground-disturbing activities.”
Introduction
Its own record backs it
“This project does not make the decision to grant leases or authorize any exploration or development activities; it only authorizes the BLM to provide the nominated lands for competitive bid.”
Introduction
“Impacts associated with any lease activity would occur only with subsequent geothermal exploration, development, utilization, or reclamation.”
Environmental Impacts
EffectsConsenting to lease will have no effect on species listed under the Endangered Species Act or their designated critical habitat.Why it holds +
The finding rests on consent authorizing no ground disturbance, which the Introduction backs. Appendix D says later proposals would likely need their own consultation, and stipulations add no surface occupancy in whitebark pine habitat and designated critical habitat. Nothing in the document shows consent itself reaching listed species or their habitat.
The agency says
“The USFS has determined that consenting to lease the nominated parcels will have no effect on ESA-listed species or designated critical habitat in the action area.”
Endangered Species Act (Endangered Species Act)
Its own record backs it
“Therefore, additional ESA Section 7 consultation would likely be held for any future actions.”
Appendix D: Response to Comments
“MBS-BOT-04: No Surface Occupancy: to protect mature whitebark pine trees from removal and minimize the removal of seedlings and saplings in all Whitebark Pine habitat modelled as ‘suitable’ or ‘optimal’ by the USFS Region Six Whitebark Pine Maxent Class model.”
Botany
EffectsConsenting to lease won't affect treaty rights or treaty resources of the tribes in the area.Why it holds +
The finding rests on consent authorizing no ground disturbance, which the Introduction backs. The treaty section says future development will require separate NEPA analysis and tribal consultation, and stipulation MBS-CUL-02 adds no surface occupancy for areas important to tribes. The tribes' concern that the BLM could later waive those areas is about future leases, not consent itself, and Appendix D says the BLM will consult tribes before any waiver. Nothing in the document shows consent itself reaching treaty rights or resources.
The agency says
“Consenting to Lease the nominated parcels will not impact any treaty rights or treaty resources.”
1854 Treaty of Medicine Creek and 1855 Treaty of Point Elliot
Its own record backs it
“They have also commented that removing or modifying any tribal-related NSO areas would violate treaties.”
Appendix D: Response to Comments
“BLM will consult with Tribes in determining whether to grant waivers, modifications, and exemptions to NSO stipulations, if requested, during future analysis.”
Appendix D: Response to Comments
How this was read
Read from the agency’s own decision document ↗, all 58 pages. Every quote is checked word for word against it, a claim marked contradicted stands on a quote from the same document, and a second reading argued the agency’s side of every verdict before it was published. The verdicts are our reading; the quotes are the agency’s. A court can set aside agency action it finds “arbitrary, capricious, an abuse of discretion, or otherwise not in accordance with law” (5 U.S.C. 706(2)(A) ↗), which is why these gaps are worth putting in the record.
In the agency’s own words
To explore or develop geothermal resources on National Forest lands, the USFS must consent to lease areas nominated by the BLM. This analysis does not authorize ground disturbance, but creates stipulations for authorized leasing areas. https://usfs-public.box.com/s/r56gzyn1msyfvj8md81arv1mo15tgoso
The groups on this fight
4 groups predicted likely to care in Washington
Predicted likely to care is a guess from the group's sourced work in Washington, with no link to this decision. Give straight to them; nothing routes through us.
- Cascade Forest Conservancy
Predicted likely to care · a guess
Works Washington: They work only in Washington.
- Conservation Northwest
Predicted likely to care · a guess
Hanford Reach National Monument, Washington: Submitted formal comments defending Hanford Reach National Monument during the 2017 federal monument review and publicly opposed any boundary adjustment or rescindment.
- Friends of the San Juans
Predicted likely to care · a guess
Works Washington: They work only in Washington.
- Olympic Park Advocates
Predicted likely to care · a guess
Works Washington: They work only in Washington.
Every group above is on STAND for Public Lands, with its court record, its filings and who backs it.
Who signs it
The notice names no signer PLAN could read. PLAN names a decision-maker only when the document names one.
The ground
The window has closed, so there’s no watch to set on it here.
The photograph on this page: Mule deer doe in mountain fog. It’s the country this decision sits in, not the site itself. More Than Just Parks.
In court on this ground
No court case we track is over Mt. Baker National Forest and Snoqualmie National Forest.
Who holds the vote
PLAN’s record doesn’t tie a member of Congress to this fight yet. The scorecard grades the votes and bills that decide public lands; nothing joins a vote or a bill to this decision, so there’s no member to name here without guessing.
See how your members vote ↗Forest ServiceWe track this on the agency’s own system of record, where most on-the-ground decisions live.
Know an open comment period we are missing, or spotted a wrong deadline? .
More fights that need you
Go deeper, free
See how your members of Congress vote on public lands
Every representative, graded on the votes that decide the fate of parks, forests, and refuges.
Open ↗The mapSee the places under active threat
A live map of the parks, monuments, and wild country in the crosshairs right now.
Open ↗A wrong fact, a dead link, a form that wouldn’t take your letter: one tap and it comes to the people who build PLAN, with this fight attached.