Chequamegon-Nicolet west zone aspen and fir logging nears final decision
West Zone Aspen Fir Regeneration
U.S. Forest Service· Chequamegon-Nicolet National Forest, Great Divide Ranger DistrictU.S. Forest Service project page ↗
Forest ServiceWe track this on the agency’s own system of record, where most on-the-ground decisions live.
This is not a comment period
The comment round on this one is over
What is open now is a pre-decisional objection period. Only individuals and entities that already submitted timely, specific written comments during an earlier public comment opportunity on this project may file an objection (36 CFR 218.5(a)). If you commented, this is your round. If you did not, no filing you send here will be accepted, and the honest thing for us to say is that this door is closed to you rather than to hand you a form.
An organization’s comments count for the organization only. Being a member of a group that commented does not make you eligible; you had to comment in your own name (36 CFR 218.5(c)).
Do not file on our date. Get it from the notice. The objection clock runs from the day the legal notice was published in the forest’s newspaper of record, and that publication date is the exclusive means of calculating it. Objectors may not rely on a date from any other source (36 CFR 218.6(c)). The agency has to post that notice on the web within four days of publishing it (36 CFR 218.7(d)), so it is on the project page.
For what it is worth, the Forest Service comment portal listed September 28, 2026 for this project when we read it. That is the portal’s own field, not the legal notice, and we have not reconciled the two. We would rather show you where it came from than let it stand in for the law.
The groups on this fight
4 groups work Wisconsin
By footprint, from the same match the STAND matchmaker runs; none is linked to this decision in our record yet. Give straight to them; nothing routes through us.
- Aldo Leopold Foundation
Works Wisconsin: they work only in Wisconsin.
- Honor the Earth
Works Wisconsin: on the ground in Wisconsin.
- Ice Age Trail Alliance
Works Wisconsin: they work only in Wisconsin.
- North Country Trail Association
Works Wisconsin: on the ground in Wisconsin.
Every group above is on STAND for Public Lands, with its court record, its filings and who backs it.
The Forest Service is close to approving commercial logging and cutting across three ranger districts in northern Wisconsin.
What’s at risk
Only people or organizations who submitted written comments during the earlier public participation window are eligible to file an objection now. Aspen and balsam fir stands on the Great Divide, Medford-Park Falls, and Washburn Ranger Districts face logging and regeneration treatments that would alter stand structure and wildlife habitat across the west zone.
If this goes through
Once approved, the cutting and regeneration treatments will proceed across the west zone of the Chequamegon-Nicolet National Forest, reshaping forest age and structure in ways that take decades to reverse.
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
- 1
- Holds up
- 6
- No support given
- 3
- Never analyzed
The Forest Service wants to clearcut 45,826 acres of aspen and balsam fir across three ranger districts over 15 to 20 years, adding about 123 miles of system roads and 73 miles of temporary roads. It says these aging stands are at risk of converting to other forest types and must be regenerated to meet forest plan age class goals and support early successional wildlife.
“The purpose of this project is to shift stands containing aspen (Populus sp.) and balsam fir (Abies balsamea) in the project area to desired conditions. Aspen and balsam fir are getting older and are at risk of changing to other forest types.”
Purpose and Need: Why Do We Need to Act?
Each Ask below goes into your letter when you write it with PLAN on this page, matched to what you tell it about how this land reaches you.
Alternatives
No support given
Limiting openings to 40 acres wouldn't meet the purpose and need, so no alternative besides the proposal and no action was analyzed.
The document cites Forest Service rules (36 Code of Federal Regulations 220.7) that let an environmental assessment analyze only the proposed action. For Phase 1, it defines the stands as those older than 60 years plus half of those 45 to 60, notes aspen declines around 60 years on heavier, poorly drained soils and at 80 years on better drained sites, lists the large stands in Tables 7 and 8, and argues splitting them would delay regeneration, add edge and fragment stands. Splitting Phase 2 stands is part of the proposal itself, so it doesn't undercut the Phase 1 reasoning. Still, the document gives no stand-level evidence that Phase 1 stands couldn't be cut in smaller pieces, and it doesn't analyze a smaller-opening option.
AskAnalyze an alternative that caps openings at 40 acres, at least for Phase 2 and high or moderate scenic integrity stands. Provide stand data supporting the Phase 1 conclusion.
The agency’s words, the record and the law +Hide the words
The agency says
“Therefore, restricting the treatments to 40 acres would not meet the purpose and need of the project and would not be the best method to move the project area toward desired future conditions.”
Public Notice of Temporary Openings
Elsewhere in the same document
“It is likely that after this strategy is implemented, most stands in Phase 2 will be less than 40 acres.”
Public Notice of Temporary Openings
“The Proposed Action was developed through a rigorous evaluation process of the project area involving input from silviculturists, natural resources, cultural resources, recreation, and visual specialists from each ranger district.”
Alternatives Considered but Not Analyzed in Detail
The law
“consistent with the provisions of this chapter, study, develop, and describe technically and economically feasible alternatives;” National Environmental Policy Act, 42 U.S.C. 4332(2)(F) ↗
Effects
No support given
The project would improve balsam fir regeneration, supporting a species that's culturally important to Ojibwe tribes.
The Balsam Fir and Resilience section ties the benefit to forest plan guidelines G96 and G377, which call for removing the overstory over established fir seedlings and keeping fir in aspen stands. Any fir regeneration harvest adds young fir, so some benefit is plausible. But the document doesn't settle how much fir would be treated: Table 2 lists 2,182 acres and Table 5 lists 135 acres (114 in Phase 1, 21 in Phase 2). Either figure spread over 15 to 20 years falls below the stated 200-acre annual fir goal, so the size of the benefit isn't shown.
AskReconcile the balsam fir acreage in Table 2 and Table 5. Show how the project meets the 200-acre annual fir goal and addresses the climate vulnerability the document describes for this species.
The agency’s words, the record +Hide the words
The agency says
“The Proposed Action would contribute to improving the regeneration of balsam fir, which would support the continued existence of this culturally and ecologically important species and its use by the Ojibwe tribes.”
Balsam Fir and Resilience
Elsewhere in the same document
“Applying a similar approach for balsam fir, where the desired condition is simply maintenance of that type, the annual regeneration goal would be 200 acres for the west zone under the Proposed Action.”
Total Acreage and Annual Regeneration Goal
Effects
No support given
Scenery and recreation effects would be temporary and local, lasting no more than about 10 years at any location.
The document says aspen reaches 12 feet in about five years, that adjacent Phase 1 and Phase 2 stands would show openings about 10 years at most, and that staggered timing and design features limit visible change. Table 16 puts recovery within 5 to 10 years. That supports the 10-year figure for any single cut. It doesn't account for the Phase 2 plan to cut part of a large stand and the rest 5 to 10 years later, which could keep the same area showing fresh openings for more than 10 years overall.
AskRecalculate how long openings would stay visible where Phase 1 stands border Phase 2 stands harvested in two entries, and name the trails, lakes and roads affected.
The agency’s words, the record +Hide the words
The agency says
“Overall, the project’s effects on scenery and recreation follow the temporary localized change-and-recovery trajectory common to forest management on the CNNF and would be unlikely to persist beyond 10 years after treatment (see discussion below and Table 16).”
Scenery Management Environmental Consequences
Elsewhere in the same document
“The stands greater than 40 acres in Phase 2 are healthy enough where part of larger stands less than 40 acres can be cut and, 5 to 10 years later, the rest of the area can be harvested.”
Public Notice of Temporary Openings
Show 3 more claims +Show fewer
Effects
No support given
The project follows all applicable forest plan direction, is consistent on scenery, and needs no forest plan amendment.
The consistency section reports a specialist finding that scenery management is consistent. The scenery analysis says that where scenic guidelines can't be fully met, the forest would use irregular harvest boundaries, edge shaping, vegetative screening and tree islands to keep the visual intent of high and moderate scenic integrity objectives. Meeting a guideline's intent rather than its exact terms can support a consistency finding. But the document doesn't say which stands or how many would depart from the guidelines, or explain why those departures fit the plan without an amendment.
AskIdentify every stand where forest plan scenic guidelines would be exceeded, and explain why those departures are allowed without a plan amendment.
The agency’s words, the record and the law +Hide the words
The agency says
“Design features, standards, guidelines, and management directives set forth in the LRMP (Forest Service 2004a) are designed in this project (Appendix D): no LRMP amendments would be necessary for the completion of this project.”
National Forest Management Act, LRMP Consistency
Elsewhere in the same document
“However, exceedance of the LRMP’s scenic guidelines may occur in some harvest stands where site-specific conditions limit full compliance with SIO guidelines.”
Consideration of LRMP Scenic Guidelines and SMS Elements
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) ↗
Effects
No support given
Combined with other past and planned projects, this harvest would create more scenic variety, and those projects' road work would help maintain visual quality.
The document reasons that past and planned harvests, as they regrow, add younger age classes and a broader visual mix, and it sets the time frame at five years after harvest. Table 17 lists nine projects in and near the project area, and much of their acreage wouldn't create openings, such as the approximately 44,400 acres of red pine thinning and the selection and thinning work in Moose Two Axe (approximately 25,648 acres of timber harvest treatments) and Black Torch (approximately 14,920 acres). But the document never estimates how many acres of new openings from all projects would be visible at once, and it gives no basis for saying other projects' road work would help visual quality.
AskTotal the acres of recent and planned openings from all Table 17 projects plus this one by district and time period, and show where they overlap high or moderate scenic integrity areas.
The agency’s words, the record +Hide the words
The agency says
“When combined with the proposed harvest treatments, these actions would contribute to a landscape with a broader mix of age classes and a more diverse visual pattern as stands regenerate and develop.”
Reasonably Foreseeable Future Actions
Elsewhere in the same document
“Transportation improvements associated with these actions would also help maintain visual quality along roads and travel corridors.”
Reasonably Foreseeable Future Actions
Economics
No support given
Vegetation management is needed for sustainable timber production that's critical to the nation's well-being under an executive order.
The Purpose and Need section ties the project to a forest plan objective for sustainable timber production and to Executive Order 14225. But the document gives no timber volume, sale revenue, road costs or jobs. The only cost reference is that some road changes would decrease maintenance costs.
AskDisclose expected timber volume, sale revenue, road construction and reconstruction costs, and local jobs, so the timber production rationale can be weighed against the effects.
The agency’s words +Hide the words
The agency says
“Vegetation management activities are needed to meet the LRMP objective for sustainable timber production that is critical to the nation’s well-being and needs pursuant to Executive Order (EO) 14225, “Immediate Expansion of American Timber Production.””
Purpose and Need: Why Do We Need to Act?
What the document never analyzes
Not analyzed
Local economic effects of the harvest
The project cites timber production as a national need and describes small communities throughout the forest, but it never analyzes employment, sale revenue or effects on the recreation-based local economy.
Searched all 50 pages for ‘jobs’, ‘revenue’, ‘economic’, ‘employment’. None appear.
AskAnalyze local economic effects, including timber jobs and revenue and any effects on recreation spending near high scenic integrity trails and lakes.
Not analyzed
Carbon effects of clearcutting
The document has a climate change section and calls balsam fir highly vulnerable to climate change, yet it never addresses how clearcutting 45,826 acres affects carbon stored in these forests.
Searched all 50 pages for ‘carbon’, ‘sequestration’, ‘greenhouse’. None appear.
AskEstimate carbon released by the harvest and road work and carbon regained as stands regrow over the 15 to 20 year implementation period.
Not analyzed
Treaty gathering resources besides balsam fir
The document affirms reserved treaty rights to hunt, fish and gather across the forest, but its only analysis of a tribal resource is balsam fir.
Searched all 50 pages for ‘wild rice’, ‘manoomin’, ‘birch bark’. None appear.
AskWork with tribes and the Great Lakes Indian Fish and Wildlife Commission to identify other gathered plants and hunted species in treatment stands, and analyze effects on them.
Where its own record backs the agency
Purpose and needMuch of the aspen and balsam fir is at or past its 45-year rotation age, so large-scale regeneration is needed to keep these forest types.Why it holds +
Table 3 shows 44 percent of aspen at 46 years or more against a desired 5 to 15 percent, and 80 percent of balsam fir against a desired 5 to 15 percent. Those figures differ a bit from the Purpose and Need numbers (39 plus 5 percent for aspen, 91 percent for fir), but both sets show a large surplus of old stands.
The agency says
“Within the next five years, 5 percent of aspen is approaching standard rotation age (45 years), and 39 percent of aspen is currently at or beyond standard rotation age (LRMP Objective 1.4m, pages 1-4 and 2-4; Forest Service 2004).”
Purpose and Need: Why Do We Need to Act?
Its own record backs it
“Scientific literature and field observations on the CNNF indicate that aspen stands exhibit significant decline around the age of 60 years on heavier and more poorly drained soils, and at the age of 80 years on better drained sites with a larger component of bigtooth aspen (Populus grandidentata).”
Age Class Distribution
“Despite this shift in project planning focus, relatively little progress has been made to close the young aspen gap.”
Background
Read from the agency’s own decision document ↗, all 50 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.
What to say
Make these points, in your own words
- I oppose this action as proposed, and I ask the agency to weigh the specific harms below.
- The document claims 91 percent of balsam fir stands in the project area are currently older than the 45-year standard rotation age.
- The West Fork of the Chippewa River is said to cross into the project area for a 0.22-mile reach in the Great Divide Ranger District.
- The Mondeaux River is said to cross into the project area for a 0.24-mile reach in the Medford-Park Falls Ranger District.
- One treatment stand is claimed to sit within 0.12 mile of the South Fork Flambeau River but separated from it by Forest Road 144.
Show all 8 points from the document
- Portions of the Ice Age Trail and its Chippewa Loop corridor are said to lie within High Scenic Integrity Objective areas that intersect the project.
- Clusters of private homes and cabins are said to be located near specific roads within the project area.
- Say something only you can say. The law requires the agency to consider and respond to substantive comments, and specifics are what make a comment substantive.
In the agency’s own words
Meet Forest Plan regeneration, age class, and early successional habitat improvement goals and objectives through treatment of aspen and balsam fir on the west zone.
Did the agency answer?
15 issues are on this record. The agency has not published its decision document yet, so each one stays pending until the agency answers.
Issues on the record, awaiting the decision
- PendingThe tribal consultation record described in the EA consists of a package mailed on August 6, 2025, a follow-up phone call to tribal leaders, and two annual meetings with one band.
The tribal consultation record described in the EA consists of a package mailed on August 6, 2025, a follow-up phone call to tribal leaders, and two annual meetings with one band. Fourteen sovereign tribal nations are listed as consulted in Table 1, but no analysis is presented of whether government-to-government consultation was completed or what tribal concerns were raised and how they were addressed, beyond a single paragraph on balsam fir. Given the acknowledged treaty rights for hunting, fishing, and gathering on these lands and the documented cultural significance of balsam fir, the adequacy of a mailed packet and a phone call as government-to-government consultation is not demonstrated. The agency should document the substance of tribal responses, identify any unresolved concerns, and explain specifically how treaty-reserved rights were considered in project design.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe EA states that exceedance of LRMP scenic guidelines may occur in some harvest stands where site-specific conditions limit full compliance, and that the CNNF would apply project-specific design fea
The EA states that exceedance of LRMP scenic guidelines may occur in some harvest stands where site-specific conditions limit full compliance, and that the CNNF would apply project-specific design features instead. However, no stand-level or district-level quantification of how many stands would exceed guidelines, by how much, or for how long is provided. Table 14 identifies 64 stands greater than 40 acres and 2 stands greater than 100 acres in High and High/Moderate SIO areas, but the EA does not evaluate which of those will actually violate scenic guidelines or what the cumulative visual effect of simultaneous Phase 1 and Phase 2 openings would be in the same viewshed. The agency should provide a stand-level accounting of guideline exceedances and a viewshed analysis for corridors where adjacent Phase 1 and Phase 2 stands would produce compounded 10-year openings.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe EA's cumulative effects temporal boundary is stated as 2026 to 2051, yet the implementation period for this project alone is 15 to 20 years, meaning harvest could extend to 2046, leaving only five
The EA's cumulative effects temporal boundary is stated as 2026 to 2051, yet the implementation period for this project alone is 15 to 20 years, meaning harvest could extend to 2046, leaving only five years of post-harvest recovery before the boundary closes. The document simultaneously lists ongoing projects such as Black Torch (signed 2018, 15-to-20-year implementation), Moose Two Axe (signed 2024, 15-to-20-year implementation), and Kidrick (signed 2024, 15-year implementation) as reasonably foreseeable future actions. No analysis quantifies the combined temporary opening acreage from all of these overlapping projects at any single point in time or explains why a 2051 endpoint is adequate when multiple projects will still be active then. The agency should extend the cumulative effects analysis window to encompass the full implementation period of all listed concurrent projects and quantify combined open-canopy acreage at peak overlap.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe EA's purpose and need section cites Executive Order 14225 on timber production as one of the needs driving the project, alongside LRMP objectives for ecological restoration and wildlife habitat.
The EA's purpose and need section cites Executive Order 14225 on timber production as one of the needs driving the project, alongside LRMP objectives for ecological restoration and wildlife habitat. However, no analysis is provided of whether prioritizing timber volume under that executive order could conflict with LRMP standards, the 40-acre opening limit, or wildlife habitat objectives, nor is there any disclosure of how much timber volume is expected to be produced and whether any project design was altered to maximize timber output in ways that diverge from pure ecological need. Mixing a discretionary executive order with statutory LRMP obligations without analyzing potential conflicts is an unreasoned leap. The agency should disclose projected timber volumes, explain how EO 14225 influenced project design, and analyze whether any design choices made to satisfy that order conflict with LRMP ecological and scenic standards.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe EA identifies scenery as the only resource requiring detailed analysis in this document, yet the document itself cites peer-reviewed literature showing that clearcut edges cause measurable effects
The EA identifies scenery as the only resource requiring detailed analysis in this document, yet the document itself cites peer-reviewed literature showing that clearcut edges cause measurable effects on microclimate, understory plants, and lichens ranging from 100 to 300 meters into adjacent stands. Wildlife, soils, water, invasive species, and cultural resources were all screened out of detailed analysis and relegated to Appendix C with only a brief acknowledgment. No quantitative analysis of those edge effects on adjacent sensitive habitats is presented in the EA body, even though the document acknowledges those effects exist. The agency should either prepare an EIS that analyzes these resources in detail or explain with specificity, in the EA body, why each dismissed resource does not rise to the level of significance given the 45,826-acre project footprint.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingTable 3 shows that 80 percent of balsam fir stands are already older than the 45-year rotation age and that only 1 percent are in the 0-to-10-year age class against a desired condition of 15 to 25 per
Table 3 shows that 80 percent of balsam fir stands are already older than the 45-year rotation age and that only 1 percent are in the 0-to-10-year age class against a desired condition of 15 to 25 percent. Yet the Proposed Action treats only 2,182 acres of balsam fir out of 45,826 total acres, and the document states the annual balsam fir regeneration goal is just 200 acres per year for the west zone. No analysis is provided explaining how 200 acres per year of regeneration will close the enormous existing gap when 80 percent of the current stock is already beyond rotation age. The agency should provide a quantitative analysis demonstrating that the proposed balsam fir treatment rate is sufficient to achieve the desired age class distribution within any defined planning horizon.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe EA acknowledges that despite a decade of prior aspen projects, 'relatively little progress has been made to close the young aspen gap,' yet it proposes the same treatment method, clearcutting, at
The EA acknowledges that despite a decade of prior aspen projects, 'relatively little progress has been made to close the young aspen gap,' yet it proposes the same treatment method, clearcutting, at a comparable or larger scale without analyzing why prior efforts failed or how this project will succeed where the others did not. Table 3 shows 44 percent of aspen is still at or beyond rotation age and only 6 percent is in the youngest age classes. No alternative methods or adaptive management triggers are analyzed. The agency should explain, with data from the prior projects, why clearcut regeneration is expected to achieve different results this time, or analyze at least one alternative treatment approach.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe EA states that 604 stands totaling 20,609 acres would exceed the 40-acre temporary opening limit alone or by adjacency, yet the document explicitly declines to analyze any alternative to the Propo
The EA states that 604 stands totaling 20,609 acres would exceed the 40-acre temporary opening limit alone or by adjacency, yet the document explicitly declines to analyze any alternative to the Proposed Action, citing 36 CFR 220.7(b)(2)(I) as authority to proceed without alternatives. The 40-acre limit exists precisely to constrain large openings in eastern forests, and Regional Forester review is required for exceptions. Invoking a procedural minimum to avoid alternatives analysis while simultaneously proposing exceptions to a statutory size limit across 20,609 acres is an unreasoned combination. The agency should analyze at least one alternative that meets the 40-acre limit for Phase 2 stands, which the document itself concedes are young enough to be split into smaller units.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe EA acknowledges that balsam fir is highly vulnerable to climate change, is a culturally important species to Ojibwe tribes, and that GLIFWC raised concerns during scoping about the Proposed Action
The EA acknowledges that balsam fir is highly vulnerable to climate change, is a culturally important species to Ojibwe tribes, and that GLIFWC raised concerns during scoping about the Proposed Action's impacts on it. The document then states that regenerating balsam fir supports its continued existence without providing any analysis of whether clearcut regeneration of a climate-vulnerable species at the projected rate will actually maintain viable populations under climate projections. No site-specific climate vulnerability analysis for balsam fir is presented in the EA body, and the referenced vulnerability assessments are only cited in general terms. The agency should incorporate a quantitative analysis of balsam fir regeneration success probability under climate change scenarios into the EA, consistent with the Northern Institute of Applied Climate Science strategies the document says were used.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingClusters of private homes and cabins are said to be located near specific roads within the project area.
Clusters of private homes and cabins are said to be located near specific roads within the project area.
- PendingThe West Fork of the Chippewa River is said to cross into the project area for a 0.22-mile reach in the Great Divide Ranger District.
The West Fork of the Chippewa River is said to cross into the project area for a 0.22-mile reach in the Great Divide Ranger District.
- PendingThe Mondeaux River is said to cross into the project area for a 0.24-mile reach in the Medford-Park Falls Ranger District.
The Mondeaux River is said to cross into the project area for a 0.24-mile reach in the Medford-Park Falls Ranger District.
- PendingOne treatment stand is claimed to sit within 0.12 mile of the South Fork Flambeau River but separated from it by Forest Road 144.
One treatment stand is claimed to sit within 0.12 mile of the South Fork Flambeau River but separated from it by Forest Road 144.
- PendingPortions of the Ice Age Trail and its Chippewa Loop corridor are said to lie within High Scenic Integrity Objective areas that intersect the project.
Portions of the Ice Age Trail and its Chippewa Loop corridor are said to lie within High Scenic Integrity Objective areas that intersect the project.
- PendingThe document claims 91 percent of balsam fir stands in the project area are currently older than the 45-year standard rotation age.
The document claims 91 percent of balsam fir stands in the project area are currently older than the 45-year standard rotation age.
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