Ogden Poorman vegetation project on Lincoln Ranger District
Ogden Poorman
U.S. Forest Service· Lincoln Ranger District, Helena-Lewis and Clark 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 predicted likely to care in Montana
Predicted likely to care is a guess from footprint in Montana, by the same match the STAND matchmaker runs, with no link to this decision. Give straight to them; nothing routes through us.
- American Prairie
Predicted likely to care · a guess
Works Montana: defending its own bison herd, formally protesting BLM's revocation of grazing permits on 63,000 public-land acres.
- Defenders of Wildlife
Predicted likely to care · a guess
Works Montana: named plaintiff in the Rock Creek Mine case, which turned on threatened grizzly bears and bull trout.
- Earthjustice
Predicted likely to care · a guess
Works Montana: counsel in the long-running litigation against the Rock Creek and Montanore mines proposed beneath the wilderness.
- Western Watersheds Project
Predicted likely to care · a guess
Works Montana: filed a protest against BLM's revocation of the bison grazing permits.
Every group above is on STAND for Public Lands, with its court record, its filings and who backs it.
The Forest Service wants to treat forest south of Highway 200 for insect and disease damage.
What’s at risk
Trees and wildlife habitat on the Helena-Lewis and Clark National Forest face removal or alteration through vegetation management treatments. The stated driver is high hazard insect and disease damage and mortality.
If this goes through
Vegetation treatments would be authorized across the Ogden Poorman area of the Lincoln Ranger District, changing the structure of the forest there.
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
- Categorical exclusion authority invoked
- Section 603 of HFRA (16 U.S.C. 6591b)
- Active NCDE wildlife order on same forest
- R1-2023-02 (in effect)
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 own analysis
What the notice says, and what it leaves out
The strongest findings read from the agency’s own document, each quoted word for word. The window has closed; the record of what was missing stays.
Project Overview
The agency says
“treatments that address damage and mortality from insects and disease”
The project description says the Ogden Poorman Project will use treatments that address insect and disease damage but discloses no treatment type, no acreage, and no project boundary map.
Alerts
The agency says
“R1-2023-02 - NCDE Food and Wildlife Attractant Storage Order”
The same Forest Service webpage that hosts this project notice carries an active alert: 'R1-2023-02 - NCDE Food and Wildlife Attractant Storage Order.' The Northern Continental Divide Ecosystem grizzly bear management area encompasses the Lincoln Ranger District south of Lincoln, Montana.
Project Overview
The agency says
“Lead Management Unit: Lincoln Ranger District Project Purpose: Vegetation management (other than forest products)”
The project purpose is listed as 'Vegetation management (other than forest products),' yet the CE authority being invoked, HFRA Section 603, expressly authorizes the salvage of dead and dying trees, which produces commercial timber.
Project Documents
The agency says
“Use the widget below to browse documents associated with this project. Cookies must be enabled to use this tool.”
The Project Documents section conditions public access on enabling cookies and, for mobile users, cross-website tracking.
6 holes in the agency’s own analysis
What the public could have raised, from the agency’s own document
- I oppose this action as proposed, and I ask the agency to weigh the specific harms below.
- The project description says the Ogden Poorman Project will use treatments that address insect and disease damage but discloses no treatment type, no acreage, and no project boundary map. Without knowing whether treatments involve prescribed fire, mechanical thinning, or salvage harvest, and without knowing how many acres are involved, neither the public nor the agency can determine whether the project meets categorical exclusion eligibility criteria under HFRA Section 603, or whether extraordinary circumstances exist that would require a higher level of NEPA review. The agency should publish a complete project description including treatment type, acreage, and a project boundary map before proceeding with any CE determination.
- The Project Milestones table lists NEPA Start Date and Finding/Decision Date as rows, but both date fields are blank. There is no posted comment period, no date when analysis begins, and no deadline by which the public must submit comments or objections. NEPA and the HFRA objection procedures both require the agency to provide meaningful notice and an opportunity for public participation before a categorical exclusion decision is signed. The agency should immediately post specific milestone dates and establish a formal public comment period.
- The notice invokes a categorical exclusion under Section 603 of HFRA but posts no extraordinary circumstances review and no documentation that the project meets CE eligibility criteria. Under NEPA regulations, even when a CE category facially applies, the agency must determine that no extraordinary circumstances exist that would require a higher level of analysis. The project page does not reference any grizzly bear consultation, any Biological Assessment or Biological Evaluation, or any determination of effect for federally listed or sensitive species. The agency should prepare and publicly disclose a written extraordinary circumstances analysis before signing any CE decision document.
- The same Forest Service webpage that hosts this project notice carries an active alert: 'R1-2023-02 - NCDE Food and Wildlife Attractant Storage Order.' The Northern Continental Divide Ecosystem grizzly bear management area encompasses the Lincoln Ranger District south of Lincoln, Montana. Yet the project notice contains no mention of grizzly bear habitat, no species analysis, and no reference to any Section 7 ESA consultation. A categorical exclusion is not available where extraordinary circumstances exist, and an active NCDE wildlife protection order on the same forest is direct agency acknowledgment of sensitive habitat in this area. The agency should complete and post a species-specific extraordinary circumstances review.
Show every point from the document
- The project purpose is listed as 'Vegetation management (other than forest products),' yet the CE authority being invoked, HFRA Section 603, expressly authorizes the salvage of dead and dying trees, which produces commercial timber. If any salvage harvest is planned in this insect-killed stand, the 'other than forest products' purpose label directly conflicts with the CE authority being cited and misrepresents the scope of the project to the public and to any reviewing court. The agency should clarify in writing whether commercial timber removal is proposed and, if so, correct the stated purpose and reassess whether the CE category remains appropriate.
- The Project Documents section conditions public access on enabling cookies and, for mobile users, cross-website tracking. Many residents of rural Powell and Lewis and Clark Counties and Tribal citizens rely on mobile devices as their primary means of internet access, and enabling cross-website tracking raises privacy concerns that some users cannot or will not accept. Requiring tracking as a precondition for reviewing federal NEPA records creates an unequal participation burden and may suppress comments from the communities most directly affected by this project. The agency should provide all project documents through direct download links that do not require cookies or cross-site tracking.
- 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 Ogden Poorman Project would address high hazard insect concerns with treatments that address damage and mortality from insects and disease. It is located on the Lincoln Ranger District, south of Highway 200.
Did the agency answer?
6 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 notice invokes a categorical exclusion under Section 603 of HFRA but posts no extraordinary circumstances review and no documentation that the project meets CE eligibility criteria.
The notice invokes a categorical exclusion under Section 603 of HFRA but posts no extraordinary circumstances review and no documentation that the project meets CE eligibility criteria. Under NEPA regulations, even when a CE category facially applies, the agency must determine that no extraordinary circumstances exist that would require a higher level of analysis. The project page does not reference any grizzly bear consultation, any Biological Assessment or Biological Evaluation, or any determination of effect for federally listed or sensitive species. The agency should prepare and publicly disclose a written extraordinary circumstances analysis before signing any CE decision document.
A hole PLAN found in the agency’s own notice, quote verified against the text
- PendingThe same Forest Service webpage that hosts this project notice carries an active alert: 'R1-2023-02 - NCDE Food and Wildlife Attractant Storage Order.' The Northern Continental Divide Ecosystem grizzl
The same Forest Service webpage that hosts this project notice carries an active alert: 'R1-2023-02 - NCDE Food and Wildlife Attractant Storage Order.' The Northern Continental Divide Ecosystem grizzly bear management area encompasses the Lincoln Ranger District south of Lincoln, Montana. Yet the project notice contains no mention of grizzly bear habitat, no species analysis, and no reference to any Section 7 ESA consultation. A categorical exclusion is not available where extraordinary circumstances exist, and an active NCDE wildlife protection order on the same forest is direct agency acknowledgment of sensitive habitat in this area. The agency should complete and post a species-specific extraordinary circumstances review.
A hole PLAN found in the agency’s own notice, quote verified against the text
- PendingThe project description says the Ogden Poorman Project will use treatments that address insect and disease damage but discloses no treatment type, no acreage, and no project boundary map.
The project description says the Ogden Poorman Project will use treatments that address insect and disease damage but discloses no treatment type, no acreage, and no project boundary map. Without knowing whether treatments involve prescribed fire, mechanical thinning, or salvage harvest, and without knowing how many acres are involved, neither the public nor the agency can determine whether the project meets categorical exclusion eligibility criteria under HFRA Section 603, or whether extraordinary circumstances exist that would require a higher level of NEPA review. The agency should publish a complete project description including treatment type, acreage, and a project boundary map before proceeding with any CE determination.
A hole PLAN found in the agency’s own notice, quote verified against the text
- PendingThe Project Milestones table lists NEPA Start Date and Finding/Decision Date as rows, but both date fields are blank.
The Project Milestones table lists NEPA Start Date and Finding/Decision Date as rows, but both date fields are blank. There is no posted comment period, no date when analysis begins, and no deadline by which the public must submit comments or objections. NEPA and the HFRA objection procedures both require the agency to provide meaningful notice and an opportunity for public participation before a categorical exclusion decision is signed. The agency should immediately post specific milestone dates and establish a formal public comment period.
A hole PLAN found in the agency’s own notice, quote verified against the text
- PendingThe project purpose is listed as 'Vegetation management (other than forest products),' yet the CE authority being invoked, HFRA Section 603, expressly authorizes the salvage of dead and dying trees, w
The project purpose is listed as 'Vegetation management (other than forest products),' yet the CE authority being invoked, HFRA Section 603, expressly authorizes the salvage of dead and dying trees, which produces commercial timber. If any salvage harvest is planned in this insect-killed stand, the 'other than forest products' purpose label directly conflicts with the CE authority being cited and misrepresents the scope of the project to the public and to any reviewing court. The agency should clarify in writing whether commercial timber removal is proposed and, if so, correct the stated purpose and reassess whether the CE category remains appropriate.
A hole PLAN found in the agency’s own notice, quote verified against the text
- PendingThe Project Documents section conditions public access on enabling cookies and, for mobile users, cross-website tracking.
The Project Documents section conditions public access on enabling cookies and, for mobile users, cross-website tracking. Many residents of rural Powell and Lewis and Clark Counties and Tribal citizens rely on mobile devices as their primary means of internet access, and enabling cross-website tracking raises privacy concerns that some users cannot or will not accept. Requiring tracking as a precondition for reviewing federal NEPA records creates an unequal participation burden and may suppress comments from the communities most directly affected by this project. The agency should provide all project documents through direct download links that do not require cookies or cross-site tracking.
A hole PLAN found in the agency’s own notice, quote verified against the text
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