Stop logging across 104,822 acres on Carson National Forest
Truchas to Upper Costilla Headwaters Active Management Project
U.S. Forest Service· Carson National Forest, Camino Real 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 work New Mexico
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.
- Greater Chaco Coalition
Works New Mexico: the coalition of Diné and Pueblo communities fighting drilling around Chaco.
- New Mexico Wild
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
Works New Mexico: the San Juan Basin watchdog on the ground in greater Chaco.
- WildEarth Guardians
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 wants to log and burn up to 382,874 acres across two ranger districts in northern New Mexico.
What’s at risk
Forests on the Camino Real and Questa Ranger Districts face logging on up to 104,822 acres and prescribed burning on up to 382,874 non-wilderness acres. The scale of the proposal raises concerns about long-term forest health and watershed integrity in the Truchas and Upper Costilla headwaters.
If this goes through
If approved, vegetation removal and prescribed fire treatments would alter hundreds of thousands of acres of Carson National Forest, with some changes to tree cover that could take generations 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 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
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
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.
AskAnalyze a diameter cap or old-tree retention alternative in detail, with data on how many large trees would be cut by size and age and where.
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.
AskDisclose cost comparisons and how many priority treatment acres lie within existing road reach, and analyze a reduced-road alternative in detail.
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.
AskExplain whether Table 4 covers only treated acres, and disclose modeled post-treatment fire behavior for the full project area, including untreated wilderness, piñon-juniper and spruce-fir.
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.
AskModel sediment delivery from reopening roads and steep-slope logging, especially into the twenty-five impaired segments, and reconcile the minor-risk finding with the transportation section's substantial erosion.
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.
AskDisclose treatment acres and prescriptions in owl recovery habitat, post-treatment canopy cover and large-tree numbers, and survey all recovery habitat before work begins.
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.
AskDisclose how many recorded sites fall within treatment and road areas, and commit to completed surveys and tribal consultation before each phase begins.
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.
AskMap any inventoried roadless areas in the project and disclose road building, logging and burning planned within them.
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.
AskIdentify native fish in project streams and analyze sediment, temperature and road-crossing effects on them.
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.
AskDisclose affected grazing allotments, rest periods needed after burns, and forage changes for permittees.
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
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 EA presents post-treatment fire behavior projections in Table 4 showing crown fire potential dropping from 64 percent to zero percent across the entire project area, yet the document openly states in the silviculture section that desired seral state distribution 'does not meet the desired condition in any forest type over the simulated time horizon' even after treatment. The fire model appears to assume full treatment of the landscape while the vegetation model shows treatments are too limited in scale to achieve desired stand structure. The agency must explain how fire behavior models and vegetation models used the same treatment footprint assumptions, and if they did not, it must reconcile the discrepancy or prepare an EIS that honestly characterizes residual risk.
- The document acknowledges in the silviculture section that treatment effects on stand density last only 10 to 20 years for most cover types, after which basal area and SDI exceed desired ranges again, yet the proposed action authorizes up to 382,874 acres of prescribed fire and 104,822 acres of mechanical treatment described as a 10-year program with no committed re-entry schedule or funding mechanism. The agency claims long-term ecosystem improvement without disclosing what happens when treatment effects expire. The agency should analyze the full re-treatment cycle needed to maintain stated outcomes, disclose the funding gap, and either commit to a re-entry schedule or acknowledge that the stated long-term benefits are speculative.
- The cultural resources section discloses that 535 of 1,171 recorded sites within the project boundary are undetermined or unevaluated for National Register eligibility, and that Section 106 compliance will be completed in phases after the NEPA decision is made. The agency is asking the public to comment on a project covering 491,942 acres when more than 45 percent of known sites have unknown eligibility and the area has only been surveyed in roughly 106,220 of those acres. The agency should complete or substantially advance Section 106 inventory and eligibility determinations before issuing a decision, or at minimum extend the comment period and publish the phased compliance plan so the public can evaluate whether protection measures are adequate.
- The watershed condition data disclosed in the soil and water section shows that 31 of 41 analysis watersheds are functioning at risk and 2 are impaired, and the State of New Mexico's 303(d) list identifies 25 impaired river segments and 3 impaired lakes within the project area. The EA then concludes that proposed road work and treatments will produce only minor short-term sediment increases. No quantitative sediment load analysis is provided for already-impaired waterbodies. The agency should quantify projected sediment contributions from road construction and prescribed fire to each impaired waterbody, demonstrate consistency with applicable Total Maximum Daily Loads, and explain how adding road disturbance in already-impaired watersheds meets the Clean Water Act non-degradation standard.
Show all 12 points from the document
- The document eliminates from detailed analysis an alternative with diameter caps on tree cutting by citing one 2006 study and asserting that plan desired conditions cannot be achieved using only treatments that remove small trees, yet the Mexican spotted owl section states that 74 percent of recovery habitat is forage and dispersal habitat where stands 'generally do not meet desired minimum characteristics in Table C.3 due to a low proportional representation of trees greater than 18 inches DBH.' Removing large trees in recovery habitat while citing the need to protect large trees for owl habitat is a direct internal contradiction the agency does not resolve. The agency should analyze a diameter-cap alternative in detail and explain specifically how any large-tree removal in spotted owl recovery habitat is consistent with the 2012 Recovery Plan.
- The transportation section proposes opening approximately 177 miles of roads including 137.2 miles of temporary roads, converting 69.7 miles of maintenance level 1 roads to maintenance level 2, and adding previously disturbed roadbeds to the system, yet the road effects issue identified in Table 1 lists habitat fragmentation and effects on non-motorized recreation as concerns to be addressed in sections 6.7, 6.3, 6.5, and 6.8. The EA contains no quantitative analysis of habitat fragmentation caused by the net road increase, no edge-effect calculation, and no cumulative road density metric for any watershed. The agency should provide a quantitative road density and fragmentation analysis by watershed, disclose net change in road miles open at project end, and analyze cumulative effects on wildlife movement corridors including for the northern goshawk and Canada lynx.
- The air quality section compares proposed action annual emissions from roughly 8,552 acres of prescribed fire to a no-action wildfire modeled at approximately 100,000 acres, presenting the comparison in Tables 9 and 10 as the primary basis for concluding the proposed action improves air quality outcomes. This comparison is not equivalent: one is a certain annual event and the other is a low-probability worst-case scenario. The EA provides no probability-weighted expected annual emissions comparison, no analysis of cumulative smoke exposure across the multi-year project life, and no analysis of impacts to the four Class I wilderness areas downwind. The agency should provide an expected-value emissions comparison, analyze cumulative smoke exposure over the 10-plus-year project life, and assess potential impacts to Class I air quality areas including the Wheeler Peak, Pecos, Bandelier, and…
- The Silverspot butterfly section states that only 627 acres, or 38 percent, of potential suitable habitat have been surveyed with negative results, meaning 62 percent of potential habitat has not been surveyed. The document then states that if more than 3 years pass before work begins in potential habitat, new surveys are required under the 2024 interim recovery plan. Given that this is a 10-plus-year phased project and the butterfly was only listed as threatened in 2024, the EA does not disclose what proportion of unsurveyed potential habitat overlaps with early treatment phases or how the agency will ensure survey requirements are met before each phase. The agency should map the overlap of unsurveyed Silverspot habitat against phased treatment areas, commit to a survey schedule tied to each treatment phase, and disclose the protocol for halting work if individuals are found.
- The socioeconomic section states that Tribal and traditional community consultation will occur before site-specific implementation to identify sacred sites and traditional use areas, yet the cultural resources section confirms that the NEPA decision will be made before Section 106 is complete across the full project area. The document lists Taos Pueblo, Picuris Pueblo, and Ohkay Owingeh among those consulted but does not disclose what information was shared with them, whether they concurred with the phased approach, or whether any tribe identified concerns that remain unresolved. The agency should release the government-to-government consultation record in a form the public can review, disclose any unresolved tribal objections, and explain how the phased Section 106 approach satisfies the trust responsibility given that the project surrounds Picuris Pueblo on three sides.
- The EA assigns the 3,788-acre Miranda Canyon acquisition a recreation opportunity spectrum classification of semi-primitive motorized based solely on the presence of two proposed administrative-use roads and several temporary project roads, yet the recreation section states a recreation opportunity spectrum classification has never been assigned to this area and no recreation opportunity objectives currently exist for it. The agency is using project infrastructure it proposes to build as the justification for a permanent land classification designation that will govern future management, without any public baseline inventory, visitor use data, or alternatives analysis for that classification. The agency should separately analyze and provide a comment opportunity on the Miranda Canyon recreation opportunity spectrum designation, disclose whether the semi-primitive motorized…
- 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.
Did the agency answer?
10 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 cultural resources section discloses that 535 of 1,171 recorded sites within the project boundary are undetermined or unevaluated for National Register eligibility, and that Section 106 compliance
The cultural resources section discloses that 535 of 1,171 recorded sites within the project boundary are undetermined or unevaluated for National Register eligibility, and that Section 106 compliance will be completed in phases after the NEPA decision is made. The agency is asking the public to comment on a project covering 491,942 acres when more than 45 percent of known sites have unknown eligibility and the area has only been surveyed in roughly 106,220 of those acres. The agency should complete or substantially advance Section 106 inventory and eligibility determinations before issuing a decision, or at minimum extend the comment period and publish the phased compliance plan so the public can evaluate whether protection measures are adequate.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe document acknowledges in the silviculture section that treatment effects on stand density last only 10 to 20 years for most cover types, after which basal area and SDI exceed desired ranges again,
The document acknowledges in the silviculture section that treatment effects on stand density last only 10 to 20 years for most cover types, after which basal area and SDI exceed desired ranges again, yet the proposed action authorizes up to 382,874 acres of prescribed fire and 104,822 acres of mechanical treatment described as a 10-year program with no committed re-entry schedule or funding mechanism. The agency claims long-term ecosystem improvement without disclosing what happens when treatment effects expire. The agency should analyze the full re-treatment cycle needed to maintain stated outcomes, disclose the funding gap, and either commit to a re-entry schedule or acknowledge that the stated long-term benefits are speculative.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe watershed condition data disclosed in the soil and water section shows that 31 of 41 analysis watersheds are functioning at risk and 2 are impaired, and the State of New Mexico's 303(d) list ident
The watershed condition data disclosed in the soil and water section shows that 31 of 41 analysis watersheds are functioning at risk and 2 are impaired, and the State of New Mexico's 303(d) list identifies 25 impaired river segments and 3 impaired lakes within the project area. The EA then concludes that proposed road work and treatments will produce only minor short-term sediment increases. No quantitative sediment load analysis is provided for already-impaired waterbodies. The agency should quantify projected sediment contributions from road construction and prescribed fire to each impaired waterbody, demonstrate consistency with applicable Total Maximum Daily Loads, and explain how adding road disturbance in already-impaired watersheds meets the Clean Water Act non-degradation standard.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe document eliminates from detailed analysis an alternative with diameter caps on tree cutting by citing one 2006 study and asserting that plan desired conditions cannot be achieved using only treat
The document eliminates from detailed analysis an alternative with diameter caps on tree cutting by citing one 2006 study and asserting that plan desired conditions cannot be achieved using only treatments that remove small trees, yet the Mexican spotted owl section states that 74 percent of recovery habitat is forage and dispersal habitat where stands 'generally do not meet desired minimum characteristics in Table C.3 due to a low proportional representation of trees greater than 18 inches DBH.' Removing large trees in recovery habitat while citing the need to protect large trees for owl habitat is a direct internal contradiction the agency does not resolve. The agency should analyze a diameter-cap alternative in detail and explain specifically how any large-tree removal in spotted owl recovery habitat is consistent with the 2012 Recovery Plan.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe transportation section proposes opening approximately 177 miles of roads including 137.2 miles of temporary roads, converting 69.7 miles of maintenance level 1 roads to maintenance level 2, and ad
The transportation section proposes opening approximately 177 miles of roads including 137.2 miles of temporary roads, converting 69.7 miles of maintenance level 1 roads to maintenance level 2, and adding previously disturbed roadbeds to the system, yet the road effects issue identified in Table 1 lists habitat fragmentation and effects on non-motorized recreation as concerns to be addressed in sections 6.7, 6.3, 6.5, and 6.8. The EA contains no quantitative analysis of habitat fragmentation caused by the net road increase, no edge-effect calculation, and no cumulative road density metric for any watershed. The agency should provide a quantitative road density and fragmentation analysis by watershed, disclose net change in road miles open at project end, and analyze cumulative effects on wildlife movement corridors including for the northern goshawk and Canada lynx.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe EA presents post-treatment fire behavior projections in Table 4 showing crown fire potential dropping from 64 percent to zero percent across the entire project area, yet the document openly states
The EA presents post-treatment fire behavior projections in Table 4 showing crown fire potential dropping from 64 percent to zero percent across the entire project area, yet the document openly states in the silviculture section that desired seral state distribution 'does not meet the desired condition in any forest type over the simulated time horizon' even after treatment. The fire model appears to assume full treatment of the landscape while the vegetation model shows treatments are too limited in scale to achieve desired stand structure. The agency must explain how fire behavior models and vegetation models used the same treatment footprint assumptions, and if they did not, it must reconcile the discrepancy or prepare an EIS that honestly characterizes residual risk.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe Silverspot butterfly section states that only 627 acres, or 38 percent, of potential suitable habitat have been surveyed with negative results, meaning 62 percent of potential habitat has not been
The Silverspot butterfly section states that only 627 acres, or 38 percent, of potential suitable habitat have been surveyed with negative results, meaning 62 percent of potential habitat has not been surveyed. The document then states that if more than 3 years pass before work begins in potential habitat, new surveys are required under the 2024 interim recovery plan. Given that this is a 10-plus-year phased project and the butterfly was only listed as threatened in 2024, the EA does not disclose what proportion of unsurveyed potential habitat overlaps with early treatment phases or how the agency will ensure survey requirements are met before each phase. The agency should map the overlap of unsurveyed Silverspot habitat against phased treatment areas, commit to a survey schedule tied to each treatment phase, and disclose the protocol for halting work if individuals are found.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe socioeconomic section states that Tribal and traditional community consultation will occur before site-specific implementation to identify sacred sites and traditional use areas, yet the cultural
The socioeconomic section states that Tribal and traditional community consultation will occur before site-specific implementation to identify sacred sites and traditional use areas, yet the cultural resources section confirms that the NEPA decision will be made before Section 106 is complete across the full project area. The document lists Taos Pueblo, Picuris Pueblo, and Ohkay Owingeh among those consulted but does not disclose what information was shared with them, whether they concurred with the phased approach, or whether any tribe identified concerns that remain unresolved. The agency should release the government-to-government consultation record in a form the public can review, disclose any unresolved tribal objections, and explain how the phased Section 106 approach satisfies the trust responsibility given that the project surrounds Picuris Pueblo on three sides.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe EA assigns the 3,788-acre Miranda Canyon acquisition a recreation opportunity spectrum classification of semi-primitive motorized based solely on the presence of two proposed administrative-use ro
The EA assigns the 3,788-acre Miranda Canyon acquisition a recreation opportunity spectrum classification of semi-primitive motorized based solely on the presence of two proposed administrative-use roads and several temporary project roads, yet the recreation section states a recreation opportunity spectrum classification has never been assigned to this area and no recreation opportunity objectives currently exist for it. The agency is using project infrastructure it proposes to build as the justification for a permanent land classification designation that will govern future management, without any public baseline inventory, visitor use data, or alternatives analysis for that classification. The agency should separately analyze and provide a comment opportunity on the Miranda Canyon recreation opportunity spectrum designation, disclose whether the semi-primitive motorized classification is consistent with the land management plan for that acquisition, and not use temporary project roads as the basis for a permanent classification.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe air quality section compares proposed action annual emissions from roughly 8,552 acres of prescribed fire to a no-action wildfire modeled at approximately 100,000 acres, presenting the comparison
The air quality section compares proposed action annual emissions from roughly 8,552 acres of prescribed fire to a no-action wildfire modeled at approximately 100,000 acres, presenting the comparison in Tables 9 and 10 as the primary basis for concluding the proposed action improves air quality outcomes. This comparison is not equivalent: one is a certain annual event and the other is a low-probability worst-case scenario. The EA provides no probability-weighted expected annual emissions comparison, no analysis of cumulative smoke exposure across the multi-year project life, and no analysis of impacts to the four Class I wilderness areas downwind. The agency should provide an expected-value emissions comparison, analyze cumulative smoke exposure over the 10-plus-year project life, and assess potential impacts to Class I air quality areas including the Wheeler Peak, Pecos, Bandelier, and San Pedro Parks wildernesses.
A hole PLAN found in the agency’s own analysis, quote verified against the document
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