Support prescribed burning across 30,167 acres of Chelan Ranger District
Lower North Shore Landscape Restoration
U.S. Forest Service· Chelan Ranger District, Okanogan-Wenatchee National ForestU.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 Washington
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.
- Cascade Forest Conservancy
Works Washington: they work only in Washington.
- Conservation Northwest
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
Works Washington: they work only in Washington.
- Olympic Park Advocates
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.
Planned burns on 30,167 acres would reduce catastrophic wildfire risk and improve wildlife habitat on the Okanogan-Wenatchee National Forest.
What’s at risk
Without this project, 30,167 acres of the Chelan Ranger District remain vulnerable to uncharacteristic, high-severity wildfire. Decades of fire suppression have left vegetation unhealthy and less resilient to natural disturbance.
If we stay silent
The Forest Service would conduct prescribed burns across 30,167 acres, restoring natural fire patterns and improving long-term forest and wildlife conditions on the Chelan Ranger District.
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
- 2
- Hold up
- 6
- No support given
- 1
- Never analyzed
The Forest Service wants to use prescribed fire across the full 30,167.6-acre project area on the north shore of Lake Chelan, with small-tree thinning on about 21,095.9 acres, over 20 years. It says this will reduce the risk of uncharacteristic wildfire, restore fire-dependent forests and improve wildlife habitat.
“The Forest Service proposes to mimic natural disturbance on the landscape using prescribed fire to reduce the risk of uncharacteristic wildfires, increase health and resilience of vegetation and improve wildlife habitat.”
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.
Authority
No support given
The whole project sits inside the emergency landscape and qualifies for Infrastructure Investment and Jobs Act emergency authority, exempting it from the objection process.
The Infrastructure Investment and Jobs Act section says the project is within the landscape the Secretary identified on April 3, 2025, and that use of the emergency determination was approved for this project on November 18, 2025. The finding of no significant impact repeats that approval. But the Purpose and Need section says only about 73 percent of the project falls within the emergency action determination area. The two statements may use different geographic terms ('landscape' versus 'determination area'), yet the document never explains the difference or says how the remaining roughly 27 percent is covered.
AskIdentify the acres outside the emergency determination area, explain what authority covers them, and state whether the normal objection process applies to those acres.
The agency’s words, the record +Hide the words
The agency says
“This project is within the landscape identified by Secretary Rollins on April 3, 2025, and the use of the Fuels and Forest Health Emergency Action Determination has been approved for this project.”
Infrastructure Investment and Jobs Act (IIJA), Section 40807
Elsewhere in the same document
“Approximately 73 percent of the proposed project falls within the emergency action determination area.”
Purpose and Need
Effects
No support given
The project won't affect any waters or wetlands, so no Clean Water Act permits or changes are needed.
The agency says design criteria and best management practices consistent with the National Best Management Practices for Water Quality Management would protect water quality. It also dismisses hydrology from detailed study on that basis and finds negligible effects to floodplains and wetlands. The Clean Water Act statement appears to be about permits. Still, the flat claim that the project won't affect any waters sits uneasily with the agency's own list of foreseeable effects, which includes potential temporary increases in sediment delivery to streams. It also doesn't fit the planned treatment of riparian reserves, which Table 5 lists at 2,439.6 acres, or the Executive Order 11990 finding that wetlands occur in the project area.
AskReconcile the no-effect finding with the disclosed sediment delivery, and analyze how much sediment could reach the creeks draining into Lake Chelan from riparian treatments and burns.
The agency’s words, the record and the law +Hide the words
The agency says
“The project will not affect any waters, including wetlands, and no further permits or modifications are needed to ensure compliance.”
Clean Water Act
Elsewhere in the same document
“Short-term effects include temporary visual changes to the landscape, potential temporary increases in sediment delivery to streams, localized vegetation mortality, recreational closures, and displacement of wildlife.”
NEPA: Consideration of Reasonably Foreseeable Impacts
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
The project may affect but is not likely to adversely affect whitebark pine, a threatened species, because it fits a regional programmatic biological opinion.
The agency says a regional programmatic biological opinion covers all proposed activities, and that it will meet its Endangered Species Act section 7 duty for whitebark pine by following that opinion and its conservation measures. That explains why whitebark pine isn't in the list of determinations the U.S. Fish and Wildlife Service concurred on for this project. The planting ratios apply only where botany design criteria can't be applied and killing or severely injuring whitebark pine can't be avoided. However, the programmatic opinion isn't in this text, and the document doesn't say how often those unavoidable losses are expected.
AskEstimate how many whitebark pine could be killed, explain how that fits a not-likely-to-adversely-affect finding, and document the Fish and Wildlife Service concurrence for whitebark pine.
The agency’s words, the record and the law +Hide the words
The agency says
“The proposed action is within the parameters of the proposed actions described in the programmatic and thus the proposed action may affect, but not likely to adversely affect whitebark pine.”
Whitebark Pine
Elsewhere in the same document
“For each sapling killed, eight seedlings would be planted. For each mature tree directly killed or severely damaged, an acre would be planted with a planting density of 100 whitebark pine seedlings.”
Whitebark Pine
“The proposed project may affect, not likely to adversely affect Canada lynx, Canada lynx critical habitat, northern spotted owl, and gray wolf.”
Endangered Species Act
The law
“Each Federal agency shall, in consultation with and with the assistance of the Secretary, insure that any action authorized, funded, or carried out by such agency (hereinafter in this section referred to as an "agency action") is not likely to jeopardize the continued existence of any endangered species or threatened species” Endangered Species Act, 16 U.S.C. 1536(a)(2) ↗
Show 3 more claims +Show fewer
Effects
No support given
Following the state smoke permitting process keeps the project well within National Ambient Air Quality Standards, so air quality needs no detailed analysis.
The agency says every burn needs an approved burn plan with a smoke management element and Washington Department of Ecology approval. It says burning would occur only when conditions loft and disperse smoke, that no non-attainment areas are in the vicinity, and that the state smoke plan allows about 7 percent of the particulate standard. It also limits underburning to up to 20 percent of one watershed unit in any given year. But the document lists particulate emissions and sensitive receptors as indicators and gives no emissions estimate, names no receptors, and doesn't model smoke from repeated burning of 30,167.6 acres over 20 years near homes on both sides of the lake.
AskProvide estimated particulate emissions per year, identify nearby sensitive receptors such as schools and towns, and model expected smoke concentrations in lakeshore communities.
The agency’s words, the record +Hide the words
The agency says
“Thus, by following and being permitted by the WA Smoke Management Plan, the project is well within NAAQS.”
Table 7
Elsewhere in the same document
“The Washington Smoke Management Plan allows for approximately 7 percent of the National Ambient Air Quality Standard of the concentration of PM10.”
Table 7
Economics
No support given
Prescribed fire costs substantially less than fighting a large wildfire, and the project will reduce suppression costs.
The document gives no cost figures for thinning, burning or fireline work, no suppression cost estimates, and no comparison. It also notes there's no market for most of the thinned material, so treatment costs won't be offset by sales. The economic benefit is asserted without numbers.
AskEstimate the cost of the treatments over 20 years and compare it with expected suppression cost savings, showing the basis for the comparison.
The agency’s words, the record +Hide the words
The agency says
“Prescribed fire activities are substantially less costly than fighting a large wildfire and can be conducted when budget and environmental factors allow.”
NEPA: Consideration of Reasonably Foreseeable Impacts
Elsewhere in the same document
“Minimal hauling is planned as there currently are no markets for much of the material that would result from proposed treatments.”
Road Maintenance, Haul Routes, and Temporary Roads
Process
No support given
Tribal consultation turned up no potential impacts to treaty rights, treaty resources or other Tribal rights and interests.
The agency says regular notification and consultation with potentially affected Tribes occurred throughout planning. It says government-to-government consultation was initiated, and it lists the Colville Tribes and the Yakama Nation among those engaged. Section 106 review must be completed before each implementation phase. But the consultation section documents only letters sent before the comment period, with no responses or meetings described. Historic property surveys are still underway for the northern half. The document names culturally important plants like huckleberries but doesn't analyze treaty resources.
AskDescribe what consultation with each Tribe actually involved, what they said, and how treaty resources such as culturally important plants would be affected by repeated burning.
The agency’s words, the record +Hide the words
The agency says
“The Tribal notification and consultation processes did not result in the identification of any potential impacts to treaty rights, treaty resources, or other unextinguished Tribal rights and interests.”
Pertinent Executive Orders
Elsewhere in the same document
“Prior to the comment period, Tribal consultation letters were sent to the Confederated Tribes and Bands of the Yakama Nation and Confederated Tribes of the Colville Reservation.”
Consultation with Federally Recognized Tribes
“Coordination of field surveys and identification of historic properties has been completed for the southern half of the project area and is underway for the northern half of the project area.”
National Historic Preservation Act, Section 106 Review
What the document never analyzes
Not analyzed
Carbon and greenhouse gas emissions
The project would burn 30,167.6 acres with repeat burns over 20 years and leans on climate projections to justify treatment, but it never estimates carbon released or stored.
Searched all 45 pages for ‘carbon’, ‘greenhouse’. None appear.
AskEstimate carbon emissions from prescribed burning and pile burning and compare them with projected emissions from wildfire under no action.
Where its own record backs the agency
EffectsTreatments will cut modeled active crown fire from 7 percent to 1 percent of the area and expand the area where crews can directly attack fires.Why it holds +
The Fire and Fuels section reports before-and-after fire behavior modeling: a baseline where only 7 percent of surface fire has flame lengths under 4 feet, and a post-treatment result where 42 percent of the area is amenable to direct attack. The full table is in Appendix C, which isn't in this text, but the stated model outputs back the direction and rough size of the change.
The agency says
“The proposed action would reduce heavy fuels and ladder fuels to lower active crown fire from 7 percent to 1 percent, passive crown fire would decrease 30 percent and surface fire would increase 37 percent within the proposed action area.”
Environmental Consequences
Its own record backs it
“However, of the nearly 50 percent surface fire, only 7 percent is modeled as less than 4-foot flame length which is the estimated flame length that hand crews can effectively and safely suppress.”
Potentially Affected Environment
“Flame length proportions across the proposed area, amenable to direct attack (0–4 feet), would be increased by 33 percent, thus representing 42 percent of the area.”
Environmental Consequences
EffectsEffects on Canada lynx critical habitat will be insignificant because enough well-distributed snowshoe hare habitat remains after treatment.Why it holds +
The critical habitat section gives numbers: 380 acres of hare habitat lost for about 10 to 30 years, 70 percent of capable forest in the Cooper Mountain lynx analysis unit still supporting it, 51 acres of denning cover affected against 531 acres of alternatives, and project-area critical habitat equal to 2.1 percent of Unit 4. These figures support the finding.
The agency says
“Because the proposed action will maintain an adequate quantity of spatially well-distributed PCE1a, the proposed action will have an insignificant effect on this PCE within the LAU and across CHU 4.”
Canada Lynx Critical Habitat
Its own record backs it
“Post-project conditions retain all capable habitat, but the proportion currently functioning as year-round foraging habitat declines from 80 percent to 70 percent.”
Canada Lynx
Read from the agency’s own decision document ↗, all 45 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 support this action and urge the agency to advance it.
- The EA dismisses fish, aquatics, and hydrology from detailed analysis (Table 7) by asserting that project design criteria 'will avoid or minimize impacts,' but the document itself acknowledges that short-term effects include 'potential temporary increases in sediment delivery to streams' and that the project spans three sub-watersheds draining directly into Lake Chelan, a municipal and recreational water source. The agency provides no quantitative analysis of sediment loading, no stream temperature modeling, and no assessment of cumulative water-quality effects across the 30,167-acre treatment area. Dismissing these issues to a one-sentence entry in Table 7 while acknowledging sediment delivery impacts in the FONSI is internally contradictory. The agency should either provide a detailed aquatic and hydrological effects analysis in the EA or prepare an EIS that fully evaluates…
- The EA uses the IIJA Section 40807 emergency authority to bypass the pre-decisional objection process, yet 73 percent of the project area falls within the emergency determination area, meaning up to 27 percent does not. The document states only that 'approximately 73 percent of the proposed project falls within the emergency action determination area' but provides no analysis of why the remaining acreage qualifies for the same streamlined process or whether that portion should be subject to normal objection procedures. The agency should clearly delineate which acres are covered by the emergency authority and apply standard objection procedures to all acres outside the determination area.
- Section 106 consultation under the National Historic Preservation Act is explicitly incomplete: the EA states that 'coordination of field surveys and identification of historic properties has been completed for the southern half of the project area and is underway for the northern half.' The agency nonetheless issues a FONSI and plans to begin implementation in spring 2027. Tribal Historic Preservation Officers are promised only 30 days to review survey results that have not yet been produced. Proceeding to a FONSI before completing cultural resource surveys for the full project area violates the requirement to identify and evaluate historic properties before approving an undertaking. The agency should complete Section 106 surveys and consultation for the entire project area before signing any decision, not on a rolling phased basis after approval.
- Canada lynx critical habitat was revised in July 2026, reducing the designated area by 32 percent, after ESA consultation was already completed. The EA acknowledges this revision and states that 'the effects analyzed in the current biological assessment are now overestimates,' and that consultation was reinitiated with concurrence received September 8, 2026. However, the EA provides no updated acreage figures, no revised effects analysis, and no explanation of how the reinitiated consultation affected the original determinations. Stating that prior analysis is an overestimate without providing corrected numbers does not constitute a transparent effects disclosure. The agency should release the updated biological assessment with revised acreage and effects figures for public review before finalizing the decision.
Show all 11 points from the document
- The EA dismisses air quality from detailed analysis in Table 7 by citing compliance with the Washington Smoke Management Plan, yet the project proposes prescribed burning across 30,167.6 acres over 20 years adjacent to the City of Chelan and lakeside communities. The dismissal contains no quantitative modeling of cumulative PM10 or PM2.5 emissions from overlapping burns within the same airshed, no analysis of smoke impacts on sensitive receptors such as children, the elderly, or people with respiratory conditions, and no assessment of combined smoke loading with the adjacent Cooper Ridge and A-to-A projects burning simultaneously. Compliance with a permitting framework is not a substitute for a site-specific cumulative air quality analysis. The agency should prepare a quantitative cumulative smoke emissions analysis covering all overlapping projects and sensitive receptor populations…
- The EA treats recreation impacts as non-substantive and dismisses them from detailed analysis in Table 7, acknowledging only 'temporary disruptions' and 'prescribed burns may temporarily displace recreationists.' The project covers 30,167.6 acres adjacent to Lake Chelan, a major recreation destination, and proposes burning over a 20-year implementation window. No analysis quantifies the frequency, duration, or geographic extent of trail and road closures, no economic estimate is provided for recreation displacement, and no cumulative analysis addresses how closures from this project interact with the adjacent Cooper Ridge and A-to-A projects. The agency should provide a detailed recreation effects analysis, including estimated closure durations and spatial extents, or justify in writing why these effects are truly negligible.
- The EA's vegetation analysis states that the timeframe for anticipating effects is 40 years, yet the FONSI and EA elsewhere describe a 20-year implementation window and cite climate projections to mid-century. The EA further states that 'by mid-century, the majority of the planning area is projected to have moisture stress levels that are currently associated woodland/shrub-steppe,' implying substantial portions of the project area may convert to non-forest regardless of treatment. The document does not analyze whether thinning and prescribed fire treatments will remain effective if the plant community shifts to shrub-steppe within the treatment timeframe, or whether reforestation efforts will survive projected moisture stress. The agency should analyze treatment effectiveness under the agency's own mid-century climate projections and disclose the probability that treated areas convert…
- The EA states that 9,071.7 acres are 'too steep or remote for initial thinning' and will receive broadcast burn only, yet acknowledges that in these areas 'prescribed fires would ensure burn objectives include residual tree densities as prescribed in silviculture prescriptions.' No silvicultural prescription is disclosed in the EA for these broadcast-burn-only acres, no analysis explains how fire alone will achieve desired residual densities without prior mechanical treatment, and no risk assessment addresses the higher probability of unintended tree mortality on steep, remote terrain where suppression resources cannot easily respond if conditions exceed prescription. The agency should provide the silvicultural prescriptions and a site-specific effects analysis for the 9,071.7 acres proposed for broadcast burn without prior thinning.
- The EA's tribal consultation section states that consultation 'did not result in the identification of any potential impacts to treaty rights, treaty resources, or other unextinguished Tribal rights and interests,' yet the project area includes culturally important plants explicitly named in the EA, such as huckleberries, and spans traditional territory of the Confederated Tribes of the Colville Reservation and Confederated Tribes and Bands of the Yakama Nation. The document provides no record of what information was shared with Tribes, what responses were received, or how Traditional Ecological Knowledge was incorporated into the analysis. A bare assertion that consultation occurred and found no impacts, with no supporting documentation in the public EA, does not satisfy the government-to-government consultation standard. The agency should release a summary of Tribal consultation…
- 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 to mimic natural disturbance on the landscape using prescribed fire to reduce the risk of uncharacteristic wildfires, increase health and resilience of vegetation and improve wildlife habitat on 30,167 acres of the Chelan Ranger District.
Did the agency answer?
9 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 EA dismisses fish, aquatics, and hydrology from detailed analysis (Table 7) by asserting that project design criteria 'will avoid or minimize impacts,' but the document itself acknowledges that sh
The EA dismisses fish, aquatics, and hydrology from detailed analysis (Table 7) by asserting that project design criteria 'will avoid or minimize impacts,' but the document itself acknowledges that short-term effects include 'potential temporary increases in sediment delivery to streams' and that the project spans three sub-watersheds draining directly into Lake Chelan, a municipal and recreational water source. The agency provides no quantitative analysis of sediment loading, no stream temperature modeling, and no assessment of cumulative water-quality effects across the 30,167-acre treatment area. Dismissing these issues to a one-sentence entry in Table 7 while acknowledging sediment delivery impacts in the FONSI is internally contradictory. The agency should either provide a detailed aquatic and hydrological effects analysis in the EA or prepare an EIS that fully evaluates water-quality and fisheries impacts.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe EA uses the IIJA Section 40807 emergency authority to bypass the pre-decisional objection process, yet 73 percent of the project area falls within the emergency determination area, meaning up to 2
The EA uses the IIJA Section 40807 emergency authority to bypass the pre-decisional objection process, yet 73 percent of the project area falls within the emergency determination area, meaning up to 27 percent does not. The document states only that 'approximately 73 percent of the proposed project falls within the emergency action determination area' but provides no analysis of why the remaining acreage qualifies for the same streamlined process or whether that portion should be subject to normal objection procedures. The agency should clearly delineate which acres are covered by the emergency authority and apply standard objection procedures to all acres outside the determination area.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingSection 106 consultation under the National Historic Preservation Act is explicitly incomplete: the EA states that 'coordination of field surveys and identification of historic properties has been com
Section 106 consultation under the National Historic Preservation Act is explicitly incomplete: the EA states that 'coordination of field surveys and identification of historic properties has been completed for the southern half of the project area and is underway for the northern half.' The agency nonetheless issues a FONSI and plans to begin implementation in spring 2027. Tribal Historic Preservation Officers are promised only 30 days to review survey results that have not yet been produced. Proceeding to a FONSI before completing cultural resource surveys for the full project area violates the requirement to identify and evaluate historic properties before approving an undertaking. The agency should complete Section 106 surveys and consultation for the entire project area before signing any decision, not on a rolling phased basis after approval.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingCanada lynx critical habitat was revised in July 2026, reducing the designated area by 32 percent, after ESA consultation was already completed.
Canada lynx critical habitat was revised in July 2026, reducing the designated area by 32 percent, after ESA consultation was already completed. The EA acknowledges this revision and states that 'the effects analyzed in the current biological assessment are now overestimates,' and that consultation was reinitiated with concurrence received September 8, 2026. However, the EA provides no updated acreage figures, no revised effects analysis, and no explanation of how the reinitiated consultation affected the original determinations. Stating that prior analysis is an overestimate without providing corrected numbers does not constitute a transparent effects disclosure. The agency should release the updated biological assessment with revised acreage and effects figures for public review before finalizing the decision.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe EA dismisses air quality from detailed analysis in Table 7 by citing compliance with the Washington Smoke Management Plan, yet the project proposes prescribed burning across 30,167.6 acres over 20
The EA dismisses air quality from detailed analysis in Table 7 by citing compliance with the Washington Smoke Management Plan, yet the project proposes prescribed burning across 30,167.6 acres over 20 years adjacent to the City of Chelan and lakeside communities. The dismissal contains no quantitative modeling of cumulative PM10 or PM2.5 emissions from overlapping burns within the same airshed, no analysis of smoke impacts on sensitive receptors such as children, the elderly, or people with respiratory conditions, and no assessment of combined smoke loading with the adjacent Cooper Ridge and A-to-A projects burning simultaneously. Compliance with a permitting framework is not a substitute for a site-specific cumulative air quality analysis. The agency should prepare a quantitative cumulative smoke emissions analysis covering all overlapping projects and sensitive receptor populations before finalizing the FONSI.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe EA treats recreation impacts as non-substantive and dismisses them from detailed analysis in Table 7, acknowledging only 'temporary disruptions' and 'prescribed burns may temporarily displace recr
The EA treats recreation impacts as non-substantive and dismisses them from detailed analysis in Table 7, acknowledging only 'temporary disruptions' and 'prescribed burns may temporarily displace recreationists.' The project covers 30,167.6 acres adjacent to Lake Chelan, a major recreation destination, and proposes burning over a 20-year implementation window. No analysis quantifies the frequency, duration, or geographic extent of trail and road closures, no economic estimate is provided for recreation displacement, and no cumulative analysis addresses how closures from this project interact with the adjacent Cooper Ridge and A-to-A projects. The agency should provide a detailed recreation effects analysis, including estimated closure durations and spatial extents, or justify in writing why these effects are truly negligible.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe EA's vegetation analysis states that the timeframe for anticipating effects is 40 years, yet the FONSI and EA elsewhere describe a 20-year implementation window and cite climate projections to mid
The EA's vegetation analysis states that the timeframe for anticipating effects is 40 years, yet the FONSI and EA elsewhere describe a 20-year implementation window and cite climate projections to mid-century. The EA further states that 'by mid-century, the majority of the planning area is projected to have moisture stress levels that are currently associated woodland/shrub-steppe,' implying substantial portions of the project area may convert to non-forest regardless of treatment. The document does not analyze whether thinning and prescribed fire treatments will remain effective if the plant community shifts to shrub-steppe within the treatment timeframe, or whether reforestation efforts will survive projected moisture stress. The agency should analyze treatment effectiveness under the agency's own mid-century climate projections and disclose the probability that treated areas convert to non-forest despite the investment.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe EA states that 9,071.7 acres are 'too steep or remote for initial thinning' and will receive broadcast burn only, yet acknowledges that in these areas 'prescribed fires would ensure burn objective
The EA states that 9,071.7 acres are 'too steep or remote for initial thinning' and will receive broadcast burn only, yet acknowledges that in these areas 'prescribed fires would ensure burn objectives include residual tree densities as prescribed in silviculture prescriptions.' No silvicultural prescription is disclosed in the EA for these broadcast-burn-only acres, no analysis explains how fire alone will achieve desired residual densities without prior mechanical treatment, and no risk assessment addresses the higher probability of unintended tree mortality on steep, remote terrain where suppression resources cannot easily respond if conditions exceed prescription. The agency should provide the silvicultural prescriptions and a site-specific effects analysis for the 9,071.7 acres proposed for broadcast burn without prior thinning.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe EA's tribal consultation section states that consultation 'did not result in the identification of any potential impacts to treaty rights, treaty resources, or other unextinguished Tribal rights a
The EA's tribal consultation section states that consultation 'did not result in the identification of any potential impacts to treaty rights, treaty resources, or other unextinguished Tribal rights and interests,' yet the project area includes culturally important plants explicitly named in the EA, such as huckleberries, and spans traditional territory of the Confederated Tribes of the Colville Reservation and Confederated Tribes and Bands of the Yakama Nation. The document provides no record of what information was shared with Tribes, what responses were received, or how Traditional Ecological Knowledge was incorporated into the analysis. A bare assertion that consultation occurred and found no impacts, with no supporting documentation in the public EA, does not satisfy the government-to-government consultation standard. The agency should release a summary of Tribal consultation records and explain how Tribal input was or was not incorporated into project design before finalizing the decision.
A hole PLAN found in the agency’s own analysis, quote verified against the document
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