Comments closed October 26 · decided
Little White Salmon Watershed nears decision on Phase 2 thinning and logging
U.S. Forest Service · Little White Salmon Watershed, Gifford Pinchot National Forest
- What
- The Forest Service is close to approving commercial logging and fuels treatments across 1,411 more acres in the Little White Salmon Watershed.
- Where
- Little White Salmon Watershed, Gifford Pinchot National Forest, WA
- How much
- 1,411 acres mature forest thinning in Phase 2; up to 3,187 acres spotted owl incidental take (harm)
- Decided
- Comments closed October 26, 2026. The decision is on file: Appendix J. Response to Public Comment. Open it ↗Date from Forest Service legal notice in The Columbian ↗, read September 26, 2026.
Where these four lines come from
- WhatOur plain-English read of the Forest Service project page ↗. Check it against the agency’s own words under Case.
- WhereThe places and states the project page names, as PLAN read them.
- 1,411 acres“I have decided to authorize thinning, fuel management and associated activities on an additional 1,411 acres in the Little White Salmon project area.” Phase 2 draft Decision Notice, Decision, p. 2 Open the source ↗
- up to 3,187 acres“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” Wildlife Species Open the document ↗
- DecidedOctober 26, 2026, from Forest Service legal notice in The Columbian, published September 9, 2026, plus 45 days under 36 CFR 218.6 ↗. Read September 26, 2026. The decision document is the one on file in PLAN’s record.
- Read from PLAN’s record November 9, 2026.
What the proposal said, and what the decision did
No figure from the proposal has been checked against the decision on this fight yet. What the record does hold is the issues ledger below.
Did the agency answer?
PLAN found 4 issues in the agency’s analysis.
Each issue against the decision, unreviewed
PLAN’s match, not yet checked by a personThe 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 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
“The Proposed Action balanced management to meet the project's purpose and need with NSO conservation considerations, as required through the Endangered Species Act's Section 7 consultation process with the U.S Fish and Wildlife Service.”
The agency’s own words, Appendix J. Response to Public Comment ↗, RS0131 · PLAN’s match, unchecked, an answer in part
PLAN found no answer, not yet checked by a personThe 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.
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
PLAN’s match, not yet checked by a personThe 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.
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
“We acknowledge errors could have been made regarding old growth delineation with the methodologies explained in Appendix F. Unfortunately, on-the-ground validation of every acre classified as mature or old growth was not possible prior to resource analyses. Project design criteria and mitigations are in place to ensure we do not impact resources we intended to avoid.”
The agency’s own words, Appendix J. Response to Public Comment ↗, RS0014 · PLAN’s match, unchecked
PLAN’s match, not yet checked by a personThe 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.
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
“Flame lengths may eventually exceed the no-treatment level as accumulated fuel loads are affected by increased winds at the surface, particularly following heavier thinning. Reductions in canopy fuels mitigate impacts of higher flame lengths and crown fire potential generally remains low (see fuels report for additional discussion). Re-entry with maintenance treatments is proposed, as conditions dictate, to keep surface fuel loading and associated flame lengths low.”
The agency’s own words, Appendix J. Response to Public Comment ↗, RS0079 · PLAN’s match, unchecked, an answer in part
Response to comments: Appendix J. Response to Public Comment ↗
PLAN's read: high threat
The Forest Service is close to approving commercial logging and fuels treatments across 1,411 more acres in the Little White Salmon Watershed.
What’s at risk
If this goes through
Our plain-English read of the official notice ↗. Check it against the agency’s own words below.
By the numbers, from the documents on the record
- Mature forest thinning in Phase 2
Phase 2 draft Decision Notice, Decision, p. 2
Open the source ↗“I have decided to authorize thinning, fuel management and associated activities on an additional 1,411 acres in the Little White Salmon project area.”
- Spotted owl incidental take (harm)
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”
The agency’s case, tested
What the agency argues, and whether its own record backs it
- 2
- Hold up
- 4
- Not fully backed
- 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
EffectsNot fully backedThe 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.
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) ↗
EffectsNot fully backedSpotted 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.
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
EffectsNot fully backedDespite 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.
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
ProcessNot fully backedMoving 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.
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 analyzedEconomic 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.
Not analyzedLog 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.
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
How this was read
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.
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.
The groups on this fight
4 groups predicted likely to care in Washington
Predicted likely to care is a guess from the group's sourced work in Washington, 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
Hanford Reach National Monument, 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.
Who signs it
PLAN hasn’t read a signer into its record for this fight. The decision on file carries the signature: Appendix J. Response to Public Comment ↗.
The ground
The window has closed, so there’s no watch to set on it here.
The photograph on this page: Gifford Pinchot National Forest, Washington. More Than Just Parks.
In court on this ground
No court case we track is over Gifford Pinchot National Forest.
Who holds the vote
PLAN’s record doesn’t tie a member of Congress to this fight yet. The scorecard grades the votes and bills that decide public lands; nothing joins a vote or a bill to this decision, so there’s no member to name here without guessing.
See how your members vote ↗Forest ServiceWe track this on the agency’s own system of record, where most on-the-ground decisions live.
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