Each issue against the decision not yet reviewed

• PLAN’s match, not yet checked by a personThe document states that about 12 million board feet of timber will be authorized and that commercial salvage covers 3,587 acres, yet no site-specific environmental analysis is provided for the Akawa Butte Fire area.

  The document states that about 12 million board feet of timber will be authorized and that commercial salvage covers 3,587 acres, yet no site-specific environmental analysis is provided for the Akawa Butte Fire area.

  The agency relies entirely on a national programmatic Post-Fire Recovery EA rather than conducting any project-level NEPA analysis of actual site conditions, fire severity, soils, hydrology, or species populations on this specific landscape. The Treatment Acres Table shows 10,080 total acres affected, with 28,655 overlapping activity acres, yet no effects analysis, no alternatives analysis, and no mitigation rationale tied to local conditions appears anywhere in this document. The agency should prepare a project-specific EA or EIS that analyzes the actual environmental consequences of this specific project on this specific landscape.

  A hole PLAN found in the agency’s own analysis

  “Because anticipated effects of the proposed action are consistent with impacts already analyzed, and because the absence of action poses a greater risk of long-term losses, it is appropriate to rely on the Post-Fire Recovery EA’s analysis.”

  The agency’s own words, Akawa Butte Fire Recovery FONSI ↗, Finding of No Significant Impact, page 2 · PLAN’s match, unchecked, an answer in part

• PLAN found no answer, not yet checked by a personThe document exempts roadside hazard tree removal units entirely from snag retention requirements.

  The document exempts roadside hazard tree removal units entirely from snag retention requirements.

  PDC TES-15 states 'there are no retention requirements for roadside danger tree salvage,' yet roadside hazard mitigation covers 1,341 acres and 36.8 miles of open road. Cavity-nesting species and TES species that depend on snags are present in the fire area, as TES-14 and TES-15 acknowledge, but 1,341 acres of potential snag habitat gets zero retention standards with no analysis of cumulative snag loss across the project. The agency should analyze the cumulative effect of zero snag retention across all roadside units on cavity-nesting species populations and justify the blanket exemption or set minimum retention standards.

  A hole PLAN found in the agency’s own analysis

• PLAN’s match, not yet checked by a personThe temporary road activity card shows that the checkbox for 'Installing drainage features such as culverts' is unchecked, and the checkbox for 'Restore natural drainage patterns and watershed function by removing culverts or drainage structures' is also unchecked, yet the project authorizes 3.05 miles of new temporary road construction in a post-fire watershed where PDC H-10d expressly requires minimizing erosive effects through proper design and construction.

  The temporary road activity card shows that the checkbox for 'Installing drainage features such as culverts' is unchecked, and the checkbox for 'Restore natural drainage patterns and watershed function by removing culverts or drainage structures' is also unchecked, yet the project authorizes 3.05 miles of new temporary road construction in a post-fire watershed where PDC H-10d expressly requires minimizing erosive effects through proper design and construction.

  Leaving culverts and drainage restoration unchecked while operating in a hydrologically sensitive burned landscape is internally inconsistent. The agency should explain why drainage features are excluded from temporary road construction and removal on this project and analyze the erosion and sedimentation risk of that choice.

  A hole PLAN found in the agency’s own analysis

  “Temporary road construction was reduced from 3.05 miles in the original proposal to approximately 0.3 miles; a reduction of over 90 percent. This change was based, in part, about public and tribal concerns around noxious weed spread and big game forage.”

  The agency’s own words, Akawa Butte Fire Recovery FONSI ↗, Proposed Action, page 2 · PLAN’s match, unchecked, an answer in part

• PLAN found no answer, not yet checked by a personPDC TES-9 requires maintaining mixed stand conditions in burned areas, including retaining a well-distributed diversity of patch sizes and burned conditions, to support TES species habitat needs.

  PDC TES-9 requires maintaining mixed stand conditions in burned areas, including retaining a well-distributed diversity of patch sizes and burned conditions, to support TES species habitat needs.

  The proposed action removes trees up to 20 inches DBH across 3,587 acres of commercial salvage and 1,341 acres of roadside treatment using mechanical tracked harvesters and ground-based logging on 4,928 acres, yet the document contains no analysis of how patch diversity or structural heterogeneity will be maintained at any scale. No maps, no targets, and no monitoring requirements for patch retention appear anywhere in the document. The agency should provide a spatial analysis showing how the proposed harvest pattern maintains the diversity of patch sizes and burned conditions required by TES-9.

  A hole PLAN found in the agency’s own analysis

• PLAN’s match, not yet checked by a personPDC H-10a requires that cumulative detrimental soil effects from project implementation must at a minimum not exceed conditions prior to the planned activity, and that 80 percent of each activity area must retain acceptable productivity potential.

  PDC H-10a requires that cumulative detrimental soil effects from project implementation must at a minimum not exceed conditions prior to the planned activity, and that 80 percent of each activity area must retain acceptable productivity potential.

  The project authorizes landings at a rate of one per 10 to 15 acres, averaging one-half acre each, across 4,928 harvest acres, which implies roughly 330 to 490 landings totaling 165 to 245 acres of concentrated disturbance, yet no soil productivity analysis, no pre-activity detrimental soil condition baseline, and no cumulative soil impact calculation appears in the document. The agency should provide a site-specific soils analysis demonstrating that the 80 percent productivity threshold will be met across the project area given the combined footprint of landings, skid trails, and temporary roads.

  A hole PLAN found in the agency’s own analysis

  “Increases in detrimental soils condition for each proposed treatment type were estimated on a unit basis. Increase in detrimental soils condition was assumed to be a 2-10% based on past soils monitoring, proposed treatment type, and implementation of project design criteria.”

  The agency’s own words, Akawa Butte Fire Recovery FONSI ↗, Determination of Analysis Reliance, page 7, Soils · PLAN’s match, unchecked, an answer in part