Stop the plan to thin and burn across 491,942 acres of the Carson
Truchas to Upper Costilla Headwaters Active Management Project
U.S. Forest Service· Carson National Forest, Camino Real Ranger District, Questa 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.
The groups on this fight
4 groups predicted likely to care in New Mexico
Predicted likely to care is a guess from footprint in New Mexico, by the same match the STAND matchmaker runs, with no link to this decision. Give straight to them; nothing routes through us.
- Greater Chaco Coalition
Predicted likely to care · a guess
Works New Mexico: the coalition of Diné and Pueblo communities fighting drilling around Chaco.
- New Mexico Wild
Predicted likely to care · a guess
Works New Mexico: led the community campaign for the 2014 designation and executive director Mark Allison spoke at the June 2025 Las Cruces rally against monument reductions and the Senate public land sell-off provisions.
- San Juan Citizens Alliance
Predicted likely to care · a guess
Works New Mexico: the San Juan Basin watchdog on the ground in greater Chaco.
- WildEarth Guardians
Predicted likely to care · a guess
Works New Mexico: serial litigant over greater Chaco drilling permits.
Every group above is on STAND for Public Lands, with its court record, its filings and who backs it.
The Forest Service proposes mechanical treatment on up to 104,822 acres and prescribed fire on up to 382,874 acres across a 491,942-acre area, decided by Environmental Assessment rather than a full Environmental Impact Statement.
What’s at risk
The document itself shows large gaps in the evidence behind this decision: no lynx surveys have ever been done, only 10 percent of Mexican spotted owl recovery habitat has been surveyed, and only about 106,220 of 491,942 project acres have been surveyed for cultural resources. The project area already contains twenty-five impaired river segments and three impaired lakes, and the agency's own modeling shows piñon-juniper forest and forest-wide seral state structure will still not meet desired conditions even after treatment.
If this goes through
Approval sets in motion at least 10 years of mechanical thinning and prescribed burning, plus 177.1 miles of new or reopened roads across 41 watersheds, all authorized through a 30-day comment period and a phased cultural resource review that lets ground work begin before all historic properties are identified. The emergency authority cited to support the decision was granted by the Secretary in April 2025, after the Forest Supervisor's own project-specific emergency determination in November 2023, a sequence the document never explains.
Our plain-English read of the official notice ↗. Check it against the agency’s own words below.
By the numbers, from the agency’s own document
- Total project area treated
- 491,942 acres
- Mechanical vs. prescribed fire acres proposed
- 104,822 acres mechanical; 382,874 acres prescribed fire
- Total project roads built or reopened
- 177.1 miles
- Public comment period on a 491,942-acre plan
- 30 days
- Prescribed fire acres burned per year
- about 8,552 acres/year
Environmental Assessment and Need for the Proposed Action
Open the document ↗“conduct active management activities on approximately 491,942 acres in the Questa and Camino Real Ranger Districts”
Proposed Action
Open the document ↗“mechanical treatments on up to 104,822 acres and prescribed fire treatments on up to 382,874 acres”
Transportation system management (Figure 6)
Open the document ↗“Total proposed roads created for the project across all vegetation communities would be approximately 177.1 miles”
Environmental Impacts of the Proposed Action
Open the document ↗“there would be approximately 8,552 acres of prescribed fire annually”
Each figure is checked word for word against the decision document ↗; open a label to read the sentence it comes from and the document it’s in.
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 thin forests on up to 104,822 acres and use prescribed fire on up to 382,874 acres across the Questa and Camino Real Ranger Districts. It says this will cut wildfire risk to communities, infrastructure and watersheds and restore fire-adapted forests.
“The Carson National Forest proposes to reduce hazardous fuels and restore ecosystems within high-risk firesheds on the two east zone ranger districts using prescribed fire and other vegetation management treatments.”
Proposed Action
Alternatives
No support given
A 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.
The agency’s words, the record +Hide the words
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
Alternatives
No support given
An 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.
The agency’s words, the record +Hide the words
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
Effects
No support given
Fire 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.
The agency’s words, the record +Hide the words
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
Show 3 more claims +Show fewer
Effects
No support given
With 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.
The agency’s words, the record and the law +Hide the words
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) ↗
Effects
No support given
Treatments 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.
The agency’s words, the record +Hide the words
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
Effects
No support given
Overall, 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.
The agency’s words, the record and the law +Hide the words
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 ↗
What the document never analyzes
Not analyzed
Inventoried roadless areas
The project would build new road through largely untouched corridors and reopen 107.2 miles of closed roads across 491,942 acres, but never says whether any of this falls in inventoried roadless areas.
Searched all 80 pages for ‘roadless’, ‘inventoried roadless’. None appear.
Not analyzed
Native trout and fish habitat
The document names outstanding national resource waters, 111 miles of eligible wild and scenic rivers and twenty-five impaired river segments, and lists fisheries as consistent, yet analyzes no fish species.
Searched all 80 pages for ‘trout’, ‘cutthroat’, ‘native fish’, ‘fish passage’. None appear.
Not analyzed
Effects on livestock grazing allotments
The socioeconomic indicators name grazing permittees and the project uses prescribed grazing and burning on forage lands, but it never analyzes effects on permitted grazing.
Searched all 80 pages for ‘allotment’, ‘animal unit’. None appear.
Where its own record backs the agency
EffectsAfter treatment, average basal area would fall within the desired range for most forested vegetation communities.Why it holds +
Table 6 shows average basal area falling from 117 to 74 square feet per acre in ponderosa pine (desired 22-89), 148 to 95 in dry mixed conifer (desired 40-124) and 151 to 134 in wet mixed conifer (desired 80-140). Spruce-fir stays in range. Piñon-juniper stays above range at 102. Gains last 10 to 20 years.
The agency says
“As demonstrated in Table 6, average basal area is within the desired range for most forested vegetation communities after treatment (year 2030).”
Resource Indicator and Measure 1a: Basal Area
Its own record backs it
“Average basal area values remain within the desired range for 10 to 20 years (most cover types exceed the desired range by 2046), reflecting the lifespan of treatment effects.”
Resource Indicator and Measure 1a: Basal Area
Read from the agency’s own decision document ↗, all 80 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
What the public could have raised, from the agency’s own document
- I oppose this action as proposed, and I ask the agency to weigh the specific harms below.
- The document says the Secretary of Agriculture did not authorize use of emergency IIJA Section 40807 authority for high-risk forests until April 4, 2025, yet it also states the Forest Supervisor already approved this project's own emergency determination on November 9, 2023, more than a year before that authority existed. The agency never explains this sequence. The Forest Service should clarify the legal basis and timeline for the emergency determination, or withdraw reliance on emergency authority and process this project through ordinary NEPA channels.
- A project covering 491,942 acres, with mechanical treatment on up to 104,822 acres, prescribed fire on up to 382,874 acres, and 177.1 miles of new or reopened roads, is being analyzed in an Environmental Assessment rather than an Environmental Impact Statement, and the public is given only 30 days to review it. Given the scale, the number of impaired waterways, and the unsurveyed wildlife and cultural resources described elsewhere in the same document, the agency should prepare a full EIS and extend the comment period well beyond 30 days.
- The agency's own silviculture modeling in Table 7 admits that after treatment, average basal area in piñon-juniper forest remains above the desired range, meaning the project's own analysis shows it will not achieve forest plan desired conditions in that vegetation type even after full implementation. The Forest Service should explain why piñon-juniper is being left in an undesired condition or expand treatment there before claiming forest-wide consistency with the 2022 land management plan.
- The agency admits that current scientific knowledge on soil disturbance from tethered logging on slopes above 60 percent is sparse, yet the proposed action allows mechanical tree felling and tethered equipment on slopes up to 75 percent, including about 2,031 acres exceeding 60 percent. The Forest Service should not authorize tethered logging on the steepest slopes until it can point to adequate monitoring data, or it should exclude those acres from mechanical treatment.
Show every point from the document
- The alternative that would have capped the diameter of trees cut was eliminated from detailed analysis with only a general assertion that restoring forest structure 'necessitates the removal of some large trees,' without any quantified comparison of how many large or old trees would be removed under the proposed action versus a capped alternative. The agency should provide a quantitative comparison of large-tree retention between a diameter-cap alternative and the proposed action before rejecting it outright.
- The document discloses that the project area already contains twenty-five impaired river segments and three impaired lakes or reservoirs on the state's 303(d) list, while the proposed action adds 177.1 miles of new or reopened roads and hundreds of road-stream crossings across 41 watersheds. Beyond general references to design features and best management practices, there is no quantified cumulative sediment budget showing how much additional sediment these already-impaired waters can absorb. The agency should quantify expected sediment delivery to each impaired segment and show it will not further degrade the impairment.
- The Forest Vegetation Simulator results the agency relies on show that seral state distribution does not meet the forest plan's desired mosaic in any forest type, even 50 years after treatment. The proposed action is justified as restoring desired forest structure, but the agency's own modeling over the full analysis horizon shows that structural goal is never reached. The agency should disclose realistically how many decades or additional treatment entries would be required to actually achieve the desired seral mosaic, rather than presenting movement toward it as sufficient justification.
- 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
The Forest Service proposes vegetation and fuel reduction treatments on up to 104,822 acres and prescribed fire treatments on up to 382,874 non-wilderness acres of NFS lands on the Camino Real and Questa Ranger Districts.
On the record for this fight
1 person has filed on this fight through PLAN. The official record is still catching up.
- Al, California36 seals
Ranked on letters found on the agency’s record, then letters filed. Readers appear as first name and last initial, or as a steward in their state; switch yours off in your record. All boards
Did the agency answer?
7 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 agency admits that current scientific knowledge on soil disturbance from tethered logging on slopes above 60 percent is sparse, yet the proposed action allows mechanical tree felling and tethered
The agency admits that current scientific knowledge on soil disturbance from tethered logging on slopes above 60 percent is sparse, yet the proposed action allows mechanical tree felling and tethered equipment on slopes up to 75 percent, including about 2,031 acres exceeding 60 percent. The Forest Service should not authorize tethered logging on the steepest slopes until it can point to adequate monitoring data, or it should exclude those acres from mechanical treatment.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe alternative that would have capped the diameter of trees cut was eliminated from detailed analysis with only a general assertion that restoring forest structure 'necessitates the removal of some l
The alternative that would have capped the diameter of trees cut was eliminated from detailed analysis with only a general assertion that restoring forest structure 'necessitates the removal of some large trees,' without any quantified comparison of how many large or old trees would be removed under the proposed action versus a capped alternative. The agency should provide a quantitative comparison of large-tree retention between a diameter-cap alternative and the proposed action before rejecting it outright.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe document says the Secretary of Agriculture did not authorize use of emergency IIJA Section 40807 authority for high-risk forests until April 4, 2025, yet it also states the Forest Supervisor alrea
The document says the Secretary of Agriculture did not authorize use of emergency IIJA Section 40807 authority for high-risk forests until April 4, 2025, yet it also states the Forest Supervisor already approved this project's own emergency determination on November 9, 2023, more than a year before that authority existed. The agency never explains this sequence. The Forest Service should clarify the legal basis and timeline for the emergency determination, or withdraw reliance on emergency authority and process this project through ordinary NEPA channels.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingA project covering 491,942 acres, with mechanical treatment on up to 104,822 acres, prescribed fire on up to 382,874 acres, and 177.1 miles of new or reopened roads, is being analyzed in an Environmen
A project covering 491,942 acres, with mechanical treatment on up to 104,822 acres, prescribed fire on up to 382,874 acres, and 177.1 miles of new or reopened roads, is being analyzed in an Environmental Assessment rather than an Environmental Impact Statement, and the public is given only 30 days to review it. Given the scale, the number of impaired waterways, and the unsurveyed wildlife and cultural resources described elsewhere in the same document, the agency should prepare a full EIS and extend the comment period well beyond 30 days.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe agency's own silviculture modeling in Table 7 admits that after treatment, average basal area in piñon-juniper forest remains above the desired range, meaning the project's own analysis shows it w
The agency's own silviculture modeling in Table 7 admits that after treatment, average basal area in piñon-juniper forest remains above the desired range, meaning the project's own analysis shows it will not achieve forest plan desired conditions in that vegetation type even after full implementation. The Forest Service should explain why piñon-juniper is being left in an undesired condition or expand treatment there before claiming forest-wide consistency with the 2022 land management plan.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe document discloses that the project area already contains twenty-five impaired river segments and three impaired lakes or reservoirs on the state's 303(d) list, while the proposed action adds 177.
The document discloses that the project area already contains twenty-five impaired river segments and three impaired lakes or reservoirs on the state's 303(d) list, while the proposed action adds 177.1 miles of new or reopened roads and hundreds of road-stream crossings across 41 watersheds. Beyond general references to design features and best management practices, there is no quantified cumulative sediment budget showing how much additional sediment these already-impaired waters can absorb. The agency should quantify expected sediment delivery to each impaired segment and show it will not further degrade the impairment.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe Forest Vegetation Simulator results the agency relies on show that seral state distribution does not meet the forest plan's desired mosaic in any forest type, even 50 years after treatment.
The Forest Vegetation Simulator results the agency relies on show that seral state distribution does not meet the forest plan's desired mosaic in any forest type, even 50 years after treatment. The proposed action is justified as restoring desired forest structure, but the agency's own modeling over the full analysis horizon shows that structural goal is never reached. The agency should disclose realistically how many decades or additional treatment entries would be required to actually achieve the desired seral mosaic, rather than presenting movement toward it as sufficient justification.
A hole PLAN found in the agency’s own analysis, quote verified against the document
The reporting behind this
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