The agency’s case, tested

What the agency argues, and whether its own record backs it

1

Holds up

6

Not fully backed

3

Never analyzed

• AlternativesNot fully backedA limit on the size of trees cut was rejected because young large trees are overabundant and plan goals require cutting some of them.

  The agency says forest plan desired conditions for density, patchiness, species composition and fire regimes can't be met without removing some large trees, cites one study, and gives retention preference to the oldest and largest trees. But it gives no count of young large trees to back the claim that they're overabundant. Its owl analysis notes a low share of trees over 18 inches in forage and dispersal stands.

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  The agency says

  “Young large trees are more plentiful than they would have been in the past and the purpose and need of restoring forest structure and maintaining healthy forests necessitates the removal of some large trees.”

  Alternative with diameter caps on tree cutting

  Elsewhere in the same document

  “These stands generally do not meet desired minimum characteristics in Table C.3 due to a low proportional representation of trees >18” DBH.”

  Mexican Spotted Owl

• AlternativesNot fully backedAn alternative with no new or temporary roads was rejected because removing material without roads would be inefficient and cost prohibitive.

  The agency says roads are needed to reach and remove material and to supply wood to local communities, and its transportation analysis says many treatments wouldn't happen without access to critical areas. But it gives no cost figures to show removal without new roads would be cost prohibitive. Existing system roads reach approximately 119,949 acres, though the document says those aren't necessarily the acres that need treatment.

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  The agency says

  “An alternative without any new or temporary roads was considered, but because any method of removing material without roads would be inefficient and cost prohibitive, treating without the use of additional roads was eliminated from detailed analysis.”

  Alternative with no new or temporary road construction

  Elsewhere in the same document

  “The total area currently accessible for project activities (entirely due to existing roads currently included on the Carson National Forest road system, some of which are designated for administrative use only) is equal to approximately 119,949 acres (31.3 percent of the total non-wilderness project area).”

  Environmental Impacts of the No-action Alternative

• EffectsNot fully backedFire modeling shows treatment would eliminate crown fire potential and cut worst-case flame lengths to 8 feet or less across the whole project area.

  The agency says its fire modeling uses the best available science to compare alternatives and warns it isn't meant to describe actual fire behavior on any acre. Table 4 still reports 0 percent active or passive crown fire and 0 percent flame lengths over 8 feet for the whole project area after treatment. No treatments are proposed in wilderness, which covers 22.2 percent of the area, and piñon-juniper and spruce-fir show minimal improvement. The document doesn't explain what treatment extent the model assumed or how untreated areas reach those results.

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  The agency says

  “Its purpose is to inform the deciding official in the decision-making process by applying the best and most readily available science and technology, along with professional judgement and experience to compare differences between the no action and proposed action alternatives.”

  Fire and Fuels Effects Addressed

  Elsewhere in the same document

  “Designated wilderness areas cover 22.2 percent of the project area (109,068 acres total).”

  Land Management Plan Consistency

  “The piñon-juniper (PJO/PJS) and spruce-fir forest cover types show minimal improvement compared to no action due to a lack of proposed treatments in these cover types, as they are largely outside of the project’s priority treatment areas.”

  Resource Indicator and Measure 1a: Basal Area

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  • EffectsNot fully backedWith design features, logging, roads and burning would cause only minor, short-term sediment risk and long-term soil gains.

    The agency relies on design features such as working only on dry or frozen soils, rut-depth limits, crossing design, rehabilitation and decommissioning temporary roads within 3 years. The transportation analysis calls road-opening effects temporary and localized, but also says reopened roads would likely have nonfunctional drainage causing substantial road-surface erosion. The document gives no sediment estimates for the twenty-five impaired river segments, and it admits research on tethered logging on steep slopes is limited.

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    The agency says

    “As a result, only minor, short‑term increases in sediment risk are expected during active operations, with long‑term improvements in soil stability due to fuel reduction and vegetation recovery.”

    Resource Indicator: Sediment and Temperature

    Elsewhere in the same document

    “Due to this lack of maintenance, many existing drainage strategies and road-stream crossing designs would likely be nonfunctional when roads are opened (causing substantial erosion of the road surface and threatening the structural integrity of the roads).”

    Environmental Impacts of the Proposed Action

    “Although research on soil disturbance associated with tethered or winch assisted logging on slopes between 40 and 60 percent is increasing, current scientific knowledge remains limited, and information for slopes exceeding 60 percent is sparse.”

    Soil and Water Effects Addressed

    The law

    “An agency shall issue an environmental impact statement with respect to a proposed agency action requiring an environmental document that has a reasonably foreseeable significant effect on the quality of the human environment.” National Environmental Policy Act, 42 U.S.C. 4336(b)(1) ↗

  • EffectsNot fully backedTreatments would keep enough of what Mexican spotted owls need while lowering the risk of losing nesting and roosting habitat to severe fire.

    The agency says prescriptions follow the 2012 recovery plan through design feature Wildlife-3, that surveys will be done by protocol before work in unsurveyed habitat, and that design criteria apply if owls are found. But it doesn't say how many of the 126,026 acres of recovery habitat would be cut or burned, or what canopy cover and large-tree numbers would remain. Only 10 percent is surveyed, and owls were detected near the boundary in 2016, 2018 and 2021.

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    The agency says

    “Therefore, the project retains a sufficient balance of density and distribution of important features that spotted owls may require while reducing the risk of losing existing roosting and nesting habitat from stand replacing fires.”

    Mexican Spotted Owl

    Elsewhere in the same document

    “Within the Truchas project boundary, there are 126,026 acres of Mexican spotted owl recovery habitat including riparian areas, with 10 percent surveyed and negative for Mexican spotted owls.”

    Mexican Spotted Owl

    “A region-wide occupancy surveys detected owls near the Truchas project boundary in 2016 (unknown sex), 2018 (male), and 2021 (female).”

    Mexican Spotted Owl

  • EffectsNot fully backedOverall, cultural resources in the project area would benefit from the project.

    The agency reasons that fuel reduction shields sites from severe wildfire and that surveys will happen phase by phase. But surveys cover about 106,220 of 491,942 acres, 535 of 1,171 recorded sites are unevaluated, and the same section lists damage from machinery, roads, erosion and looting. The net-benefit conclusion comes before any site-level review.

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    The agency says

    “Overall, cultural resources within the Truchas-Costilla project area would receive beneficial effects from the implementation of the proposed actions.”

    Environmental Impacts of the Proposed Action

    Elsewhere in the same document

    “A cursory analysis of this data reveals a total of 786 surveys (~106,220 acres) have been conducted within the Truchas-Costilla Project APE and 1171 sites have been previously recorded on the forest, within that same boundary (Table 11).”

    Affected Environment

    “Planned landscape restoration activities would continue to be assessed at the individual final project design and implementation phase.”

    Environmental Impacts of the Proposed Action

    The law

    “shall take into account the effect of the undertaking on any historic property.” National Historic Preservation Act, 54 U.S.C. 306108 ↗