Stop the 25-year Swamped logging plan near Libby, Montana
Swamped
U.S. Forest Service· Kootenai 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 Idaho and Montana
Predicted likely to care is a guess from footprint in Idaho and 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.
- 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.
- Idaho Conservation League
Predicted likely to care · a guess
Works Idaho: mobilized Idahoans to file Interior Department comments defending Craters of the Moon during the 2017 national monument review, arguing shrinkage would damage the economies of Blaine, Butte, Minidoka, and Power counties.
- Western Watersheds Project
Predicted likely to care · a guess
Works Idaho: challenging BLM's grazing management across 1.4 million acres of the Jarbidge and Bruneau river canyonlands, where it won an injunction blocking ranchers from grazing beyond their permit limits.
Every group above is on STAND for Public Lands, with its court record, its filings and who backs it.
The Swamped project would log 6,883 acres, including 173 acres inside existing old growth, and create openings up to 252 acres. It runs under an emergency determination that skips the public objection process, so this comment period is the public's say.
What’s at risk
The project would harvest 6,883 acres of the 8,569 acres treated overall, including 173 acres inside existing old growth stands and 49 acres of other old growth treatments. It would build 10.8 miles of new permanent road and create clearcut openings up to 252 acres in size in a landscape whose own cited fire history shows fires historically returned every 12 years at low intensity, not as large stand-replacing events. The agency's own table finds the project may affect, and is likely to adversely affect, the threatened grizzly bear.
If this goes through
Implementation would begin in 2027 and continue for up to 20 years of harvest plus 5 more years of follow-up work, a 25-year commitment authorized by a single environmental assessment with no described reanalysis checkpoint. Because the project was developed under an emergency situation determination, it is not subject to the standard 36 CFR 218 objection process available for most Forest Service decisions.
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 treated in initial treatments
- 8,569 acres
- Acres proposed for timber harvest
- 6,883 acres
- Size and total acreage of clearcut-style openings
- 40 to 252 acres each, 2,113 acres total
- Old growth acres logged or treated
- 173 acres harvest + 49 acres other treatment
- New permanent road miles built
- 10.8 miles
- Total implementation timeframe
- 20 years harvest + 5 years follow-up (25 years)
Proposed Activities
Open the document ↗“Under the proposal, a total of 8,569 acres would be treated through initial treatments (Table 1 and Table 2).”
Harvest Treatments
Open the document ↗“About 6,883 acres are proposed for harvest treatments (Table 1).”
Table 6
Open the document ↗“some units include more than one harvest treatment (Table 6) and range in size from 40 to 252 acres.”
Treatment of Existing Old Growth Stands
Open the document ↗“Approximately 173 acres of harvest and 49 acres of other vegetation treatments are proposed within existing old growth.”
New Forest System Road Construction
Open the document ↗“Approximately 10.8 miles of new permanent system road would be built for harvesting purposes (Table 9).”
Proposed Activities
Open the document ↗“last up to 20 years for harvest treatments and an additional 5 years to complete harvest associated treatments”
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
- 6
- No support given
- 1
- Contradicted by its own record
- 2
- Never analyzed
The Kootenai National Forest proposes to log about 6,883 acres and treat 8,569 acres in all, 15 miles south of Libby, Montana, over up to 25 years, building approximately 10.8 miles of new permanent road. It says the work is needed to shift dense Douglas-fir forests toward ponderosa pine and western larch, lower wildfire risk near homes, improve big game winter range and supply timber.
“Wildfire, insects, and disease are natural components of these ecosystems, and the proposed action would provide long-term benefits by improving the forest’s ability to withstand these disturbances while also creating safer, more effective conditions for fire management.”
Determination of No Significant Impacts
Effects
Contradicted by its own record
The project won't affect any waters, including wetlands, so no further Clean Water Act permits or changes are needed.
The hydrology summary says sediment increases would be brief and kept down by best management practices. But the finding of no significant impact itself predicts higher sediment delivery to streams. The aquatics summary expects short-term effects from culvert work, and the project puts wood directly into Elliot Creek. Those effects can't coexist with a finding that no waters are affected.
The agency’s words, the record and the law +Hide the words
The agency says
“The hydrologist has reviewed the proposed action and 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 increases in traffic and off-road equipment use would produce temporary adverse impacts to hydrologic and soil resources, including higher sediment delivery to streams and increased soil disturbance.”
Determination of No Significant Impacts
“The proposal to add small woody material to the stream, such that it interacts with the stream bed and floodplain, would help increase floodplain complexity and fine sediment retention in Elliot Creek.”
Elliot Creek Small Wood Addition
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) ↗
Purpose and need
No support given
A century of fire suppression has built up hazardous fuels, so treatments are needed to lower wildfire risk to people and private land near Libby.
The fire history backs this. The largest fire year was 1917, only about 500 acres have burned since then, and a nearby study found a fire return interval averaging 12 years. About 91 percent of treatments are in the wildland urban interface. One flaw: the finding of no significant impact names Forest Road 2253, Big Beaver Creek Road and White Pine Creek Road, which the environmental assessment never mentions.
The agency’s words, the record +Hide the words
The agency says
“Because of fire suppression, most of the area has not burned for the last 100 plus years.”
Hazardous Forest Fuels
Elsewhere in the same document
“The largest fire year for the project area was in 1917 with about 1,130 acres burning, mostly on National Forest System lands.”
Hazardous Forest Fuels
“Over 7,870 acres or 91 percent of the vegetation treatments are proposed within the wildland urban interface on National Forest System lands in a combination of harvest (6,265 acres), pre-commercial thin (395 acres), slashing (1,117 acres), and ecosystem burning (95 acres).”
Vegetation Management Treatments
Effects
No support given
The finding of no significant impact says the effects on every species listed under the Endangered Species Act are not likely to be adverse.
The species write-ups describe only brief, minor, localized disturbance for grizzly bear and minimal overlap with whitebark pine habitat. The Endangered Species Act section says a biological assessment was prepared and consultation is complete. Table 18 gives grizzly bear and whitebark pine the code "MALAA" and gives lynx and wolverine "MANLAA." The document doesn't define either code, so this text can't show the blanket "not likely to adversely affect" statement is wrong. It also doesn't explain why the codes differ.
The agency’s words, the record and the law +Hide the words
The agency says
“Effects on ESA-listed species are “Not Likely to Adversely Affect,” and no irreversible habitat loss is expected.”
Wildlife and Habitat
Elsewhere in the same document
“Grizzly Bear (Ursus arctos horribilis) Threatened MALAA The action area lies within the Fisher Bears Outside Recovery Zone (BORZ) polygon of the Cabinet-Yaak Ecosystem (CYE) and the Libby Grizzly Bear Analysis Unit (GBAU).”
Table 18
“Whitebark Pine (Pinus albicaulis) Threatened MALAA A small portion of the project area overlaps with potential habitat.”
Table 18
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 4 more claims +Show fewer
Effects
No support given
Detrimental soil disturbance won't exceed the Forest Plan's 15 percent threshold, so no long-term soil impacts are expected.
The soil design features limit slopes, equipment passes and skid trail spacing. Where monitoring shows disturbance above 15 percent, they require restoration back to 15 percent or less. But the soil restoration section says some units could exceed 15 percent after harvest, and the design features name units 39, 67 and 101 as currently over the threshold or predicted to exceed it. Units already over 15 percent only have to be restored to their pre-existing level. The finding of no significant impact doesn't reconcile those units with its statement that disturbance won't exceed 15 percent.
The agency’s words, the record and the law +Hide the words
The agency says
“Sediment levels are expected to return to pre-project conditions within one to two years following implementation, and detrimental soil disturbance is not expected to exceed the Forest Plan’s 15-percent threshold; therefore, long-term impacts to soils are not anticipated.”
Determination of No Significant Impacts
Elsewhere in the same document
“Required in units currently exceeding or predicted to exceed 15 percent detrimental soil disturbance following proposed activities.”
Soils
“Soil restoration for harvest units currently exceeding the 15 percent detrimental soil disturbance guideline for soil productivity; monitoring of the restoration work; other potential soil monitoring of Knutson-Vandenberg projects.”
Table 17
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
The project will have no effect on yellow-billed cuckoo because no work will happen in riparian areas.
Riparian buffers keep out ground-based equipment and commercial harvest. Cutting in riparian habitat conservation areas is limited to hand slashing of trees 4 inches or less, no closer than 25 feet from the flood prone area, with no piling or jackpot burning. Still, the document plans hand slashing inside riparian habitat conservation areas. It also plans to fell about 30 trees per mile from the Elliot Creek riparian habitat conservation area and place them to interact with the stream bed and floodplain. That doesn't square with the stated reason that no work will occur in riparian areas.
The agency’s words, the record and the law +Hide the words
The agency says
“Although the project area overlaps with Yellow-billed cuckoo area of influence, project activities will not be occurring in riparian areas.”
Table 18
Elsewhere in the same document
“Limited hand slashing would occur within riparian habitat conservation areas to reduce small tree ladder fuels.”
Slashing within Riparian Habitat Conservation Areas
“Approximately 30 trees per mile would be hand felled whole from the riparian habitat conservation area in overstocked areas, selecting trees generally 6 inches in diameter at breast height or less.”
Elliot Creek Small Wood Addition
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
Every regeneration opening, including those up to 252 acres, will fit the Forest Plan's desired patch sizes for its biophysical setting.
A design feature caps group L at 200 acres in the warm/dry setting, where the desired patch size is 20 to 200 acres. But Table 6 also lists group C at 218 acres, D at 237 and O at 239. The project area is mostly warm/dry, yet the document never gives these groups' settings or applies a similar cap to them.
The agency’s words, the record and the law +Hide the words
The agency says
“All patch sizes would be consistent with Forest Plan desired conditions for the biophysical setting in which they occur.”
Regeneration Harvest and Openings Greater than 40 Acres
Elsewhere in the same document
“In order to meet the desired patch size of 20-200 acres for the warm/dry biophysical setting (FW-DC-VEG-11), the combined acreage within the warm/dry biophysical setting of units 76, 77, 78, and 171 cannot exceed 200 acres.”
Forest Vegetation
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
Harvest and other treatments in old growth won't cost any stand its old growth status, and the amount of old growth will stay the same.
The document cites a Forest Plan guideline (FW-GDL-VEG-01) that allows treatment in old growth only if old growth characteristics are kept. It says all prescriptions are designed to keep stands meeting the definition and describes thinning from below around large ponderosa pine, western larch and Douglas-fir. Table 7 shows zero stands no longer meeting old growth criteria. Units 11A, 78 and 171 need old growth surveys first, and the prescriptions there would be adjusted or the treatment dropped based on the results. The document doesn't give before-and-after stand measures, but its binding design commitments support the claim.
The agency’s words and the law +Hide the words
The agency says
“The amount of old growth and recruitment potential old growth thoroughly inventoried in the project area would remain the same under the action alternative with greater likelihood of persisting into the future under a changing climate.”
Treatment of Existing Old Growth Stands
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) ↗
What the document never analyzes
Not analyzed
Contamination from the Libby Superfund site
The document notes the Libby area is on the Superfund list because of a former vermiculite mine but never says whether contamination reaches the project area or could be stirred up by logging, dust or burning.
Searched all 78 pages for ‘asbestos’, ‘amphibole’, ‘tremolite’. None appear.
Not analyzed
Groundwater and household water sources
Many residences sit along U.S. Highway 2 on the project's western edge, and road work crosses springs, but the document never discusses groundwater or household water downslope.
Searched all 78 pages for ‘groundwater’, ‘aquifer’, ‘domestic well’. None appear.
Read from the agency’s own decision document ↗, all 78 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
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 agency uses an emergency designation to strip the public of the normal right to formally object to this decision, even though Swamped is a routine, decades-long vegetation and road program rather than an emergency response to an acute event. The FONSI states the project was developed under an emergency situation determination and is therefore exempt from the pre-decisional objection process at 36 CFR 218, but the document provides no site-specific emergency finding explaining why an 8,569-acre, 25-year program covering harvest, road construction, and old growth treatment qualifies as an emergency. The agency should document the specific emergency conditions that justify skipping the objection process, or restore the standard 36 CFR 218 objection period for this project.
- The agency's own hydrology analysis and its wildlife determination table contradict each other on the same resource. The Hydrology section admits the project would cause sediment increases during road construction and could accelerate snowmelt and increase water yield, but the effects table for bull trout, a threatened species, flatly states the project area will not affect stream habitats at all. Both statements cannot be fully true at once, and the agency should reconcile the admitted sediment and hydrologic changes with the bull trout no-effect finding, or explain with data why documented sediment and flow changes do not reach bull trout habitat.
- The agency's own effects table finds the project 'may affect, likely to adversely affect' grizzly bears, a threatened species, inside the Fisher Bears Outside Recovery Zone and the Libby Grizzly Bear Analysis Unit, yet the responsible official still issues a Finding of No Significant Impact and proceeds by EA rather than a more rigorous review. The agency should explain how a likely-adverse-effect determination for a threatened species is consistent with a finding of no significant impact, and make the underlying Biological Assessment available for public review alongside the EA.
- The agency proposes commercial harvest and other vegetation treatments inside 173 acres of existing old growth (plus 20 acres of recruitment potential old growth) while asserting that old growth character will be maintained and that the total amount of old growth will stay the same. But the agency's own Table 7 shows these same acres are counted as being 'treated to promote early seral species,' meaning the species composition of stands legally defined as old growth is being deliberately altered. The agency should disclose the specific post-treatment structural and compositional data proving that logged old growth stands will still meet the Forest Plan's old growth definition, not just assert the acreage total is unchanged.
Show every point from the document
- The agency already knows, before a single tree is cut, that some harvest units will exceed the region's 15 percent detrimental soil disturbance standard, yet it only commits to restoration as something that 'may' occur depending on future monitoring rather than as a required action. This leaves specific named units (including 39, 67, and 101) at risk of remaining out of compliance with the Forest Plan soil standard with no guaranteed fix. The agency should make soil restoration mandatory, not discretionary, on every unit identified as exceeding or predicted to exceed the 15 percent threshold, and commit to a monitoring schedule before, not just after, harvest.
- The agency justifies large regeneration openings, some up to 252 acres, by claiming they mimic natural mixed-severity fire patterns, but its own background section cites a nearby fire history study showing a fire return interval averaging just 12 years, a regime dominated by frequent, low-intensity underburns rather than large stand-replacing openings. The agency should reconcile the claimed 'mixed-severity fire' rationale for 40-to-252-acre clearcuts with its own cited 12-year, low-intensity fire return interval, or provide fire severity data that actually supports openings of this size.
- The agency acknowledges that creating large canopy openings may increase illegal motorized cross-country travel, but it does not analyze this risk further, commit to any monitoring, or propose specific mitigation beyond general access management language elsewhere in the document. Given that the project creates 2,113 acres of openings over 40 acres and stores or decommissions dozens of miles of road, the agency should directly analyze and commit to concrete measures to prevent illegal cross-country motorized use in newly opened areas rather than noting the risk without a plan.
- The agency's own weeds analysis identifies ground-based logging and new road construction, the two largest components of this project, as carrying the highest risk of noxious weed introduction and spread, and admits its design features would not fully eliminate that risk. Despite this admission, the overall conclusion for the project is that impacts would not be significant. The agency should quantify expected weed spread acreage under the proposed action and commit to a specific monitoring and treatment timeline tied to the highest-risk activities, rather than relying on general design features it acknowledges are incomplete.
- Public scoping for this project closed in April 2021, with only ten comments received, all in support and raising just one concern about noxious weeds, yet the decision document is dated September 2026 and implementation will not begin until spring 2027, a gap of roughly six years. The document does not describe any re-scoping or renewed public engagement to confirm conditions, public interest, or resource concerns have not changed materially since 2021. The agency should reopen scoping or otherwise explain why a five-to-six-year-old, ten-comment public record remains adequate to support a 25-year implementation program.
- The agency authorizes an implementation window of up to 20 years for harvest treatments plus an additional 5 years for associated work, a 25-year commitment, based on a single environmental assessment analyzing current conditions. Given documented drought stress, insect and disease pressure, and lengthening fire seasons described elsewhere in the same document, conditions on the ground are likely to change substantially over a quarter century. The agency should commit to a defined reanalysis or monitoring checkpoint partway through this 25-year window rather than relying on one static EA to authorize the entire multi-decade program.
- 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
7,870 acre vegetation management project to address desired conditions and hazardous fuels.
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 agency's own weeds analysis identifies ground-based logging and new road construction, the two largest components of this project, as carrying the highest risk of noxious weed introduction and spr
The agency's own weeds analysis identifies ground-based logging and new road construction, the two largest components of this project, as carrying the highest risk of noxious weed introduction and spread, and admits its design features would not fully eliminate that risk. Despite this admission, the overall conclusion for the project is that impacts would not be significant. The agency should quantify expected weed spread acreage under the proposed action and commit to a specific monitoring and treatment timeline tied to the highest-risk activities, rather than relying on general design features it acknowledges are incomplete.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingPublic scoping for this project closed in April 2021, with only ten comments received, all in support and raising just one concern about noxious weeds, yet the decision document is dated September 202
Public scoping for this project closed in April 2021, with only ten comments received, all in support and raising just one concern about noxious weeds, yet the decision document is dated September 2026 and implementation will not begin until spring 2027, a gap of roughly six years. The document does not describe any re-scoping or renewed public engagement to confirm conditions, public interest, or resource concerns have not changed materially since 2021. The agency should reopen scoping or otherwise explain why a five-to-six-year-old, ten-comment public record remains adequate to support a 25-year implementation program.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe agency authorizes an implementation window of up to 20 years for harvest treatments plus an additional 5 years for associated work, a 25-year commitment, based on a single environmental assessment
The agency authorizes an implementation window of up to 20 years for harvest treatments plus an additional 5 years for associated work, a 25-year commitment, based on a single environmental assessment analyzing current conditions. Given documented drought stress, insect and disease pressure, and lengthening fire seasons described elsewhere in the same document, conditions on the ground are likely to change substantially over a quarter century. The agency should commit to a defined reanalysis or monitoring checkpoint partway through this 25-year window rather than relying on one static EA to authorize the entire multi-decade program.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe agency uses an emergency designation to strip the public of the normal right to formally object to this decision, even though Swamped is a routine, decades-long vegetation and road program rather
The agency uses an emergency designation to strip the public of the normal right to formally object to this decision, even though Swamped is a routine, decades-long vegetation and road program rather than an emergency response to an acute event. The FONSI states the project was developed under an emergency situation determination and is therefore exempt from the pre-decisional objection process at 36 CFR 218, but the document provides no site-specific emergency finding explaining why an 8,569-acre, 25-year program covering harvest, road construction, and old growth treatment qualifies as an emergency. The agency should document the specific emergency conditions that justify skipping the objection process, or restore the standard 36 CFR 218 objection period for this project.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe agency's own hydrology analysis and its wildlife determination table contradict each other on the same resource.
The agency's own hydrology analysis and its wildlife determination table contradict each other on the same resource. The Hydrology section admits the project would cause sediment increases during road construction and could accelerate snowmelt and increase water yield, but the effects table for bull trout, a threatened species, flatly states the project area will not affect stream habitats at all. Both statements cannot be fully true at once, and the agency should reconcile the admitted sediment and hydrologic changes with the bull trout no-effect finding, or explain with data why documented sediment and flow changes do not reach bull trout habitat.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe agency's own effects table finds the project 'may affect, likely to adversely affect' grizzly bears, a threatened species, inside the Fisher Bears Outside Recovery Zone and the Libby Grizzly Bear
The agency's own effects table finds the project 'may affect, likely to adversely affect' grizzly bears, a threatened species, inside the Fisher Bears Outside Recovery Zone and the Libby Grizzly Bear Analysis Unit, yet the responsible official still issues a Finding of No Significant Impact and proceeds by EA rather than a more rigorous review. The agency should explain how a likely-adverse-effect determination for a threatened species is consistent with a finding of no significant impact, and make the underlying Biological Assessment available for public review alongside the EA.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe agency proposes commercial harvest and other vegetation treatments inside 173 acres of existing old growth (plus 20 acres of recruitment potential old growth) while asserting that old growth chara
The agency proposes commercial harvest and other vegetation treatments inside 173 acres of existing old growth (plus 20 acres of recruitment potential old growth) while asserting that old growth character will be maintained and that the total amount of old growth will stay the same. But the agency's own Table 7 shows these same acres are counted as being 'treated to promote early seral species,' meaning the species composition of stands legally defined as old growth is being deliberately altered. The agency should disclose the specific post-treatment structural and compositional data proving that logged old growth stands will still meet the Forest Plan's old growth definition, not just assert the acreage total is unchanged.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe agency already knows, before a single tree is cut, that some harvest units will exceed the region's 15 percent detrimental soil disturbance standard, yet it only commits to restoration as somethin
The agency already knows, before a single tree is cut, that some harvest units will exceed the region's 15 percent detrimental soil disturbance standard, yet it only commits to restoration as something that 'may' occur depending on future monitoring rather than as a required action. This leaves specific named units (including 39, 67, and 101) at risk of remaining out of compliance with the Forest Plan soil standard with no guaranteed fix. The agency should make soil restoration mandatory, not discretionary, on every unit identified as exceeding or predicted to exceed the 15 percent threshold, and commit to a monitoring schedule before, not just after, harvest.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe agency justifies large regeneration openings, some up to 252 acres, by claiming they mimic natural mixed-severity fire patterns, but its own background section cites a nearby fire history study sh
The agency justifies large regeneration openings, some up to 252 acres, by claiming they mimic natural mixed-severity fire patterns, but its own background section cites a nearby fire history study showing a fire return interval averaging just 12 years, a regime dominated by frequent, low-intensity underburns rather than large stand-replacing openings. The agency should reconcile the claimed 'mixed-severity fire' rationale for 40-to-252-acre clearcuts with its own cited 12-year, low-intensity fire return interval, or provide fire severity data that actually supports openings of this size.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe agency acknowledges that creating large canopy openings may increase illegal motorized cross-country travel, but it does not analyze this risk further, commit to any monitoring, or propose specifi
The agency acknowledges that creating large canopy openings may increase illegal motorized cross-country travel, but it does not analyze this risk further, commit to any monitoring, or propose specific mitigation beyond general access management language elsewhere in the document. Given that the project creates 2,113 acres of openings over 40 acres and stores or decommissions dozens of miles of road, the agency should directly analyze and commit to concrete measures to prevent illegal cross-country motorized use in newly opened areas rather than noting the risk without a plan.
A hole PLAN found in the agency’s own analysis, quote verified against the document
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