Reject the 13,249-acre Little White Salmon logging and roads plan
Little White Salmon Forest Resiliency and Fire Risk Mitigation Project
U.S. Forest Service· Little White Salmon Watershed, Gifford Pinchot National Forest, Mt. Adams 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)).
Objections are due October 26, 2026. That date came off the agency’s own legal notice, which is the only source the regulation lets an objector rely on (36 CFR 218.6(c)).
The groups on this fight
4 groups predicted likely to care in Washington
Predicted likely to care is a guess from footprint in Washington, by the same match the STAND matchmaker runs, with no link to this decision. Give straight to them; nothing routes through us.
- Cascade Forest Conservancy
Predicted likely to care · a guess
Works Washington: they work only in Washington.
- Conservation Northwest
Predicted likely to care · a guess
Works Washington: submitted formal comments defending Hanford Reach National Monument during the 2017 federal monument review and publicly opposed any boundary adjustment or rescindment.
- Friends of the San Juans
Predicted likely to care · a guess
Works Washington: they work only in Washington.
- Olympic Park Advocates
Predicted likely to care · a guess
Works Washington: they work only in Washington.
Every group above is on STAND for Public Lands, with its court record, its filings and who backs it.
The Forest Service plans to treat 13,249 acres and log an estimated 75 million board feet in the Little White Salmon watershed even though its own Biological Opinion found the project will likely harm the threatened spotted owl.
What’s at risk
The project's own Biological Opinion anticipates incidental take of spotted owls on up to 3,187 acres from habitat removal and smoke, plus harassment on 4,114 acres, while 34 percent of required rare-species surveys remain incomplete in the highest-priority treatment areas. Two treatment stands already exceed the Forest Plan's 20 percent standard for damaged soil, and a popular dispersed campsite and paddling access at Disappearing Lake would be eliminated without any baseline use data.
If this goes through
The decision authorizes up to 11,657 acres of thinning, 52 miles of new temporary road, and fuel treatments that the agency's own modeling says can regain crown fire potential within 5 to 10 years, requiring further NEPA-reviewed re-entries roughly every decade over a 20-year project life. It also amends the Forest Plan to let required wildlife surveys happen after, rather than before, the decision is final.
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 acres proposed for treatment
- 13,249 acres
- Preliminary timber volume estimate
- 75 million board feet (mmbf)
- New temporary road to be built
- 52 miles in new locations
- Spotted owl incidental take (harm)
- up to 3,187 acres
- Wildlife surveys still incomplete at decision
- 34% (1,727 of 5,071 acres) unsurveyed
- Spotted owl suitable habitat lost
- net loss of 1,230 acres NRF habitat
Introduction
Open the document ↗“treating 13,249 acres of National Forest System lands on the Mt. Adams Ranger District of the Gifford Pinchot National Forest”
Proposed Action
Open the document ↗“A preliminary volume estimate for the entire project area across all thinning treatments totals 75 million board feet (mmbf)”
Proposed Action
Open the document ↗“Approximately 52 miles of temporary road would be constructed in new locations because prior access did not exist”
Wildlife Species
Open the document ↗“USFWS anticipated incidental take of spotted owl juveniles in the form of “harm” associated with up to 3,187 acres of suitable habitat exposed to thinning and multi-day burns”
Need for Forest Plan Amendments
Open the document ↗“Of the 5,071 acres requiring Survey and Manage wildlife surveys, 3,344 acres (66%) have been completed, while 1,727 acres (34%) remain to be surveyed.”
Table 12
Open the document ↗“There will be a net loss of 1,230 acres of suitable nesting, roosting, and foraging habitat.”
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
- 2
- Hold up
- 4
- No support given
- 2
- Never analyzed
The Forest Service wants to thin and treat fuels on 13,249 acres of the Little White Salmon watershed, decommission or close roads, and adopt two one-time forest plan amendments. It says dense, uniform stands left by past logging and fire exclusion are vulnerable to drought, insects and wildfire that threaten nearby communities and habitats.
“The purpose of this project is to increase forest resiliency to stressors and mitigate fire risk to highly valued resources by treating 13,249 acres of National Forest System lands on the Mt. Adams Ranger District of the Gifford Pinchot National Forest.”
Introduction
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.
Effects
No support given
The project creates no conflicts with the forest plan or other policies.
The agency says the soil estimate for the two stands comes from a calculation method that's less accurate for stands under 10 acres. It says their soils match neighboring stands and won't lose more productivity than other stands. Still, its own analysis estimates the two stands would exceed the forest plan's 20 percent limit on impacted soil, and the document offers no corrected figure or amendment.
AskShow how stands 303991B and 304528A will meet the 20 percent soil standard, or drop or redesign them, rather than stating there's no plan conflict.
The agency’s words, the record and the law +Hide the words
The agency says
“There would be no conflicts with plans, policies or other jurisdictions with the proposed action.”
Conflicts with Plans, Policies, or other Jurisdictions
Elsewhere in the same document
“However, based on how existing detrimental soil conditions are calculated, the analysis estimates that soil conditions in stands 303991B and 304528A would reach greater than the 20% Forest Plan Standard for impacted soil conditions post-treatment.”
Soils
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
Spotted owl habitat outside the 22 historic territories, and six surveyed territories, can be treated as unoccupied.
The agency ran a 2023 recording-unit survey with the Fish and Wildlife Service on the seven territories overlapping most affected habitat. One male was found. It assumed all 15 unsurveyed territories are occupied. It also found barred owls at every sample point, which it says makes recolonization highly unlikely. The Fish and Wildlife Service opinion, however, anticipates adverse effects and take in areas the agency called unoccupied.
AskExtend the owl effects analysis and breeding-season protections to areas where the Fish and Wildlife Service expects take, and repeat occupancy surveys before implementation.
The agency’s words, the record +Hide the words
The agency says
“Similarly, suitable habitat outside of the 22 spotted owl territories within the action area is considered unoccupied.”
Northern Spotted Owls
Elsewhere in the same document
“While the Biological Opinion concurred with the determinations for territories the USFS considered occupied by spotted owls, USFWS anticipated additional adverse effects to spotted owls in areas the USFS considered unoccupied (see page 73-74 for definitions of areas USFS considered occupied/unoccupied).”
Fish and Wildlife Service Consultation
Effects
No support given
Despite short-term losses, the project will increase spotted owl suitable habitat over the long term.
The agency cites fire modeling showing treated stands shift from high to low severity effects. It cites studies finding large wildfires are the primary cause of spotted owl habitat decline, and it expects thinning to help large trees persist. Table 12 still shows net losses of 1,230 acres of nesting habitat and 1,285 acres of foraging habitat. The document offers no long-term projection with and without the project, and the cited 10 to 20 year gain comes from mid-seral forests maturing.
AskModel suitable owl habitat over 20 years under both the proposed action and no action, including wildfire scenarios, and report acres gained or lost.
The agency’s words, the record +Hide the words
The agency says
“While the project will decrease the amount of spotted owl suitable habitat in the short term, it is expected to increase the amount of spotted owl suitable habitat in the long term, which is an objective that is consistent with the Spotted Owl Recovery Plan.”
Direct and Indirect Effects, Spotted Owl Suitable Habitat
Elsewhere in the same document
“Development of additional suitable habitat over the next 10 to 20 years is expected as mid-seral forests in the analysis area mature and transition from dispersal habitat to suitable habitat.”
Direct and Indirect Effects, Spotted Owl Suitable Habitat
Show 1 more claim +Show fewer
Process
No support given
Moving Survey and Manage surveys to after the decision keeps faith with the intent of those rules.
The agency's support is that surveys would still be required before any habitat-disturbing work, done to protocol, with any sites found managed as known sites. It adds that surveys closer to disturbance would better reflect current conditions. But the plan language it quotes ties surveys to searching habitat before decisions are made, and 1,727 acres, including high-priority stands, would be approved before being surveyed.
AskDefer the 1,727 unsurveyed acres to a later decision, or explain how survey findings could still drop or redesign stands and make those results public before logging.
The agency’s words, the record +Hide the words
The agency says
“This amendment would maintain consistency with the intent and objectives of the Survey and Manage provisions by protecting sensitive species while enabling timely decision-making and efficient, effective project delivery.”
Survey and Manage Survey Timing
Elsewhere in the same document
“Site-specific, pre-disturbance surveys that focus on the project unit are intended to meet the objective of “reducing the inadvertent loss of undiscovered sites by searching specified potential habitats prior to making decisions about habitat-disturbing activities” (USDA 2001, S&G page 21).”
Survey and Manage Survey Timing
“Of the 5,071 acres requiring Survey and Manage wildlife surveys, 3,344 acres (66%) have been completed, while 1,727 acres (34%) remain to be surveyed.”
Survey and Manage Survey Timing
What the document never analyzes
Not analyzed
Economic effects of the timber sales
The purpose and need cites jobs and local economic benefits and estimates 75 million board feet of volume, yet no section estimates jobs, income, sale revenue or project costs.
Searched all 102 pages for ‘revenue’, ‘employment’, ‘payroll’, ‘economic impact’. None appear.
AskEstimate jobs, income, sale revenue and costs to taxpayers, including road work and follow-up fuel treatments.
Not analyzed
Log hauling through nearby communities
The document places Willard and Mill A directly south of the project area and plans hauling on shared roads, but never analyzes truck volumes or safety in those communities.
Searched all 102 pages for ‘traffic’, ‘school bus’, ‘truck trips’. None appear.
AskDisclose expected log truck trips, haul routes through Willard and Mill A, and safety measures for residents.
Where its own record backs the agency
EffectsThinning would lower crown fire potential in treated stands compared with leaving them untreated.Why it holds +
Modeling of 180 stands shows most untreated stands support conditional crown fire through 2040, while thinned stands shift to surface fire and need far stronger winds to crown. Caveats: the modeled stands are a subset, flame lengths rebound 5 to 10 years after thinning, and follow-up fuel work needs separate review.
The agency says
“These stand-level results indicate reductions in crown fire potential in all treatment scenarios compared to the no treatment scenario.”
Fire and Fuels
Its own record backs it
“A 20-foot wind speed of around 20 mph would be needed to support active crown fire in the no treatment scenario.”
Fire and Fuels
“After thinning to 60% residual canopy cover, crowning index doubles to > 50 mph and continues to increase as residual canopy cover decreases.”
Fire and Fuels
EffectsCarbon removed by the project is tiny relative to the forest's total and would be regrown within months.Why it holds +
The section says removal would equal at most 0.2 percent of the forest's 217.55 +/- 7.1 Tg of stored carbon and that the forest would regrow it in less than half of a year. It reports stocks grew about 28.7 percent from 1990 to 2013, and past harvest cost about 0.5 percent of non-soil carbon. It doesn't state the tons removed.
The agency says
“Removal of carbon from the project area would equate to, at most, 0.2 percent of the total carbon stored in the Gifford Pinchot National Forest.”
Climate Adaptation and Carbon Stewardship
Its own record backs it
“An analysis of baseline carbon stocks and fluxes for the Gifford Pinchot National Forest (McKinley et al. 2020) indicates that baseline stocks increased by about 28.7 percent between 1990 and 2013.”
Climate Adaptation and Carbon Stewardship
Read from the agency’s own decision document ↗, all 102 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 agency's own Biological Opinion for this project found it "likely to adversely affect" northern spotted owls, a threatened species, and their designated critical habitat, anticipating incidental take of juveniles on up to 3,187 acres and harassment of adults and juveniles on up to 4,114 acres of suitable habitat. The stated purpose of an Environmental Assessment is to determine whether effects "may be significant enough to prepare an environmental impact statement," yet the document proceeds as if this adverse-effect, incidental-take finding for a threatened species is compatible with a Finding of No Significant Impact. The agency should prepare a full Environmental Impact Statement given its own conclusion that the project will likely harm a threatened species and its critical habitat.
- The Forest Service is proposing a Forest Plan amendment to let required pre-disturbance Survey and Manage wildlife surveys occur after the NEPA decision instead of before it, even though 34% of the required survey acreage remains uncompleted, including "high priority treatment locations" in the northeast watershed the agency itself identifies as having the greatest restoration need. This inverts the purpose of pre-disturbance surveys, which exist specifically to avoid authorizing habitat-disturbing activity before rare species sites are found. The agency should complete all required surveys and disclose their results before finalizing this decision, not after.
- For 617 acres of Late-Successional Reserve in the SW parcels, treatment of stands over 80 years old or removal of trees over 20 inches DBH normally requires review and approval by the Region 6 LSR Workgroup. The EA discloses that the responsible official chose not to pursue that consultation, yet left treatment of these LSR stands over 80 years old in the proposed action and analyzed it as if the requirement were satisfied. The agency should either complete the required LSR Workgroup consultation before authorizing treatment of these stands or drop them from the decision.
- The purpose and need repeatedly cites climate change as a central driver of the project, yet the climate effects analysis itself was truncated mid-process: after CEQ withdrew its greenhouse gas guidance and an executive order directed agencies to limit climate analysis, the Forest Service included only an abbreviated version of the analysis originally prepared for the Draft EA. A project justified substantially by climate-driven forest stress should not have its own climate and carbon effects analysis shortened for procedural rather than scientific reasons. The agency should restore and complete a full carbon and climate effects analysis consistent with what was originally scoped.
Show every point from the document
- The EA's entire framework for identifying, protecting, and treating "old growth" and "forests with old-growth characteristics" across thousands of acres rests on a mapping method the agency itself admits is unreliable: no accepted methodology exists to map mature and old-growth forests at the stand scale. Despite this admitted limitation, decisions about which mature stands were dropped from treatment and which were approved for harvest depend on this method. The agency should disclose the error rate and limitations of its mapping approach and explain how mistaken inclusion or exclusion of old-growth stands would be caught and corrected before or during implementation.
- The proposed action's timber volume, a central figure used to justify the project's economic rationale, is described as only a preliminary estimate that could change significantly once timber cruises are done. Committing to a decision covering road construction, logging systems, and harvest across 11,657 treatment acres based on volume figures the agency itself calls preliminary and potentially significantly different undermines the analysis tied to that volume. The agency should provide cruised, verified volume estimates before finalizing the decision or disclose a range of outcomes tied to that uncertainty.
- The agency's own fire behavior modeling shows the proposed thinning's benefits are not durable: under the 60% residual canopy cover scenario several stands regain the potential to support conditional crown fire within 5 to 10 years, and modeled flame lengths may eventually exceed the no-treatment level as surface fuels accumulate after thinning. This complicates the project's core fire-risk-mitigation rationale and depends on follow-up maintenance treatments that are not guaranteed and would require separate future NEPA review. The agency should disclose what happens to fire risk and public safety if the planned 10-15 year maintenance re-entries do not occur on schedule or at all.
- The Soils analysis finds that two treatment stands will exceed the Forest Plan's 20% standard for detrimental soil conditions after treatment, but dismisses this exceedance by asserting that calculations for small stands are less accurate, without providing data to support that claim. A documented Forest Plan standard violation should not be waived on an unsupported assertion about measurement accuracy. The agency should provide the underlying data justifying treatment of these stands as compliant despite exceeding the numeric standard, or bring them into compliance.
- The agency is pursuing a variance to remove protective spatial buffers for two Survey and Manage lichen species, which would allow known occurrences of those species to be impacted, but this variance has not been approved and the EA proceeds to a final decision before that process concludes. Finalizing a decision that depends on a not-yet-approved variance to a species protection standard is a procedural shortcut. The agency should complete the variance process, with public disclosure of its outcome, before finalizing this decision.
- The Recreation analysis proposes decommissioning Forest Road 6615, eliminating a dispersed campsite on Lost Creek and altering access to seasonal Disappearing Lake, used by canoers, kayakers, and stand-up paddleboarders, while admitting there is no data on how popular the site is and that the number of affected recreationists cannot be determined with available information. Deciding to eliminate recreation access without any baseline use data is not a reasoned basis for that tradeoff. The agency should collect baseline use data for Disappearing Lake and the Lost Creek dispersed site before deciding to decommission the access road.
- 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
Increase forest resiliency to climate-related stressors and mitigate fire risk to highly valued resources in the Little White Salmon Watershed. Proposed actions will include commercial timber harvest, fuels treatments and other restoration projects.
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 Forest Service is proposing a Forest Plan amendment to let required pre-disturbance Survey and Manage wildlife surveys occur after the NEPA decision instead of before it, even though 34% of the re
The Forest Service is proposing a Forest Plan amendment to let required pre-disturbance Survey and Manage wildlife surveys occur after the NEPA decision instead of before it, even though 34% of the required survey acreage remains uncompleted, including "high priority treatment locations" in the northeast watershed the agency itself identifies as having the greatest restoration need. This inverts the purpose of pre-disturbance surveys, which exist specifically to avoid authorizing habitat-disturbing activity before rare species sites are found. The agency should complete all required surveys and disclose their results before finalizing this decision, not after.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingFor 617 acres of Late-Successional Reserve in the SW parcels, treatment of stands over 80 years old or removal of trees over 20 inches DBH normally requires review and approval by the Region 6 LSR Wor
For 617 acres of Late-Successional Reserve in the SW parcels, treatment of stands over 80 years old or removal of trees over 20 inches DBH normally requires review and approval by the Region 6 LSR Workgroup. The EA discloses that the responsible official chose not to pursue that consultation, yet left treatment of these LSR stands over 80 years old in the proposed action and analyzed it as if the requirement were satisfied. The agency should either complete the required LSR Workgroup consultation before authorizing treatment of these stands or drop them from the decision.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe purpose and need repeatedly cites climate change as a central driver of the project, yet the climate effects analysis itself was truncated mid-process: after CEQ withdrew its greenhouse gas guidan
The purpose and need repeatedly cites climate change as a central driver of the project, yet the climate effects analysis itself was truncated mid-process: after CEQ withdrew its greenhouse gas guidance and an executive order directed agencies to limit climate analysis, the Forest Service included only an abbreviated version of the analysis originally prepared for the Draft EA. A project justified substantially by climate-driven forest stress should not have its own climate and carbon effects analysis shortened for procedural rather than scientific reasons. The agency should restore and complete a full carbon and climate effects analysis consistent with what was originally scoped.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe EA's entire framework for identifying, protecting, and treating "old growth" and "forests with old-growth characteristics" across thousands of acres rests on a mapping method the agency itself adm
The EA's entire framework for identifying, protecting, and treating "old growth" and "forests with old-growth characteristics" across thousands of acres rests on a mapping method the agency itself admits is unreliable: no accepted methodology exists to map mature and old-growth forests at the stand scale. Despite this admitted limitation, decisions about which mature stands were dropped from treatment and which were approved for harvest depend on this method. The agency should disclose the error rate and limitations of its mapping approach and explain how mistaken inclusion or exclusion of old-growth stands would be caught and corrected before or during implementation.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe proposed action's timber volume, a central figure used to justify the project's economic rationale, is described as only a preliminary estimate that could change significantly once timber cruises
The proposed action's timber volume, a central figure used to justify the project's economic rationale, is described as only a preliminary estimate that could change significantly once timber cruises are done. Committing to a decision covering road construction, logging systems, and harvest across 11,657 treatment acres based on volume figures the agency itself calls preliminary and potentially significantly different undermines the analysis tied to that volume. The agency should provide cruised, verified volume estimates before finalizing the decision or disclose a range of outcomes tied to that uncertainty.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe agency's own fire behavior modeling shows the proposed thinning's benefits are not durable: under the 60% residual canopy cover scenario several stands regain the potential to support conditional
The agency's own fire behavior modeling shows the proposed thinning's benefits are not durable: under the 60% residual canopy cover scenario several stands regain the potential to support conditional crown fire within 5 to 10 years, and modeled flame lengths may eventually exceed the no-treatment level as surface fuels accumulate after thinning. This complicates the project's core fire-risk-mitigation rationale and depends on follow-up maintenance treatments that are not guaranteed and would require separate future NEPA review. The agency should disclose what happens to fire risk and public safety if the planned 10-15 year maintenance re-entries do not occur on schedule or at all.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe Soils analysis finds that two treatment stands will exceed the Forest Plan's 20% standard for detrimental soil conditions after treatment, but dismisses this exceedance by asserting that calculati
The Soils analysis finds that two treatment stands will exceed the Forest Plan's 20% standard for detrimental soil conditions after treatment, but dismisses this exceedance by asserting that calculations for small stands are less accurate, without providing data to support that claim. A documented Forest Plan standard violation should not be waived on an unsupported assertion about measurement accuracy. The agency should provide the underlying data justifying treatment of these stands as compliant despite exceeding the numeric standard, or bring them into compliance.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe agency is pursuing a variance to remove protective spatial buffers for two Survey and Manage lichen species, which would allow known occurrences of those species to be impacted, but this variance
The agency is pursuing a variance to remove protective spatial buffers for two Survey and Manage lichen species, which would allow known occurrences of those species to be impacted, but this variance has not been approved and the EA proceeds to a final decision before that process concludes. Finalizing a decision that depends on a not-yet-approved variance to a species protection standard is a procedural shortcut. The agency should complete the variance process, with public disclosure of its outcome, before finalizing this decision.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe agency's own Biological Opinion for this project found it "likely to adversely affect" northern spotted owls, a threatened species, and their designated critical habitat, anticipating incidental t
The agency's own Biological Opinion for this project found it "likely to adversely affect" northern spotted owls, a threatened species, and their designated critical habitat, anticipating incidental take of juveniles on up to 3,187 acres and harassment of adults and juveniles on up to 4,114 acres of suitable habitat. The stated purpose of an Environmental Assessment is to determine whether effects "may be significant enough to prepare an environmental impact statement," yet the document proceeds as if this adverse-effect, incidental-take finding for a threatened species is compatible with a Finding of No Significant Impact. The agency should prepare a full Environmental Impact Statement given its own conclusion that the project will likely harm a threatened species and its critical habitat.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe Recreation analysis proposes decommissioning Forest Road 6615, eliminating a dispersed campsite on Lost Creek and altering access to seasonal Disappearing Lake, used by canoers, kayakers, and stan
The Recreation analysis proposes decommissioning Forest Road 6615, eliminating a dispersed campsite on Lost Creek and altering access to seasonal Disappearing Lake, used by canoers, kayakers, and stand-up paddleboarders, while admitting there is no data on how popular the site is and that the number of affected recreationists cannot be determined with available information. Deciding to eliminate recreation access without any baseline use data is not a reasoned basis for that tradeoff. The agency should collect baseline use data for Disappearing Lake and the Lost Creek dispersed site before deciding to decommission the access road.
A hole PLAN found in the agency’s own analysis, quote verified against the document
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