Stop 16,030 acres of post-fire logging in the Wrights Spring Fire on the Fremont-Winema National Forest

Each issue against the decision not yet reviewed

• PLAN found no answer, not yet checked by a personThe Post-Fire Recovery EA relied upon in full was completed on June 26, 2026, per Table 1, yet the Wrights Spring Fire did not begin until August 5, 2026.

  The Post-Fire Recovery EA relied upon in full was completed on June 26, 2026, per Table 1, yet the Wrights Spring Fire did not begin until August 5, 2026.

  A document finished forty days before the fire started cannot have analyzed this landscape's specific burn severity patterns, snag distribution, soil impacts, or site-specific wildlife displacement. The Potentially Affected Environment Similarity section asserts that the project area exhibits the same environmental conditions analyzed in the PFREA, but that document had no knowledge of this fire's footprint or intensity. That assertion is circular and structurally impossible given the timeline. The agency should withdraw the Determination of Analysis Reliance and prepare a site-specific Environmental Impact Statement that analyzes the actual post-fire conditions of the Wrights Spring Fire area, with a full public comment period on that document.

  A hole PLAN found in the agency’s own analysis

• PLAN found no answer, not yet checked by a personThe Endangered Species Act section states that emergency consultation with the U.S.

  The Endangered Species Act section states that emergency consultation with the U.S.

  Fish and Wildlife Service was initiated on September 14, 2026, and the responsible official signed the Determination of Analysis Reliance on September 22, 2026, only eight days later. ESA Section 7 emergency consultation requires a written biological opinion or written concurrence before irreversible actions are taken. Eight days is not sufficient for USFWS to issue a formal opinion covering 16,030 acres of timber harvest across habitat for northern spotted owls, wolves, bald eagles, and ESA-listed fish. No completed biological opinion or written concurrence is referenced anywhere in this document. The agency should complete formal ESA Section 7 consultation and obtain written USFWS concurrence or a biological opinion before any ground-disturbing activities begin.

  A hole PLAN found in the agency’s own analysis

• PLAN found no answer, not yet checked by a personThe Consultation with Federally Recognized Tribes section states that tribal consultation is on-going as of the decision date, yet the responsible official signed the DAR on September 22, 2026.

  The Consultation with Federally Recognized Tribes section states that tribal consultation is on-going as of the decision date, yet the responsible official signed the DAR on September 22, 2026.

  The project area includes 5,272 acres of Saddle Mountain Cultural Area, a management designation specific to its cultural significance to the Klamath Tribes. A decision that authorizes 16,030 acres of timber harvest and ground-disturbing activity through December 2031 cannot be finalized while the government-to-government consultation process remains open. The agency should complete tribal consultation before signing any final decision, document the outcomes in the public record, and explain how the results of that consultation shaped the project design.

  A hole PLAN found in the agency’s own analysis

• PLAN found no answer, not yet checked by a personThe Anticipated Environmental Impacts Similarity section states that the Botany, Fisheries, and Wildlife Biological Evaluations and the Biological Assessment are incorporated by reference and can be found in the project record.

  The Anticipated Environmental Impacts Similarity section states that the Botany, Fisheries, and Wildlife Biological Evaluations and the Biological Assessment are incorporated by reference and can be found in the project record.

  These are not included in this document. The public cannot review effects determinations for threatened and endangered species or evaluate whether the design criteria are sufficient to protect them. Incorporating critical ESA analysis by reference to an undisclosed project record does not allow meaningful public participation, and a finding of substantial similarity without the underlying evidence is not a reasoned basis for a decision. The agency should make all biological evaluations and the biological assessment available for public review as part of this EA and allow a comment period on those documents.

  A hole PLAN found in the agency’s own analysis

• PLAN found no answer, not yet checked by a personAppendix D states that the Draft Finding of No Significant Impact is contained in a separate document in the project record and is not part of this EA.

  Appendix D states that the Draft Finding of No Significant Impact is contained in a separate document in the project record and is not part of this EA.

  The FONSI is the document that justifies proceeding with an EA rather than a full EIS and that formally concludes the action will have no significant environmental effects. Without it in this document, the public cannot evaluate the agency's reasoning for why 16,030 acres of post-fire timber harvest across management areas that include bald eagle habitat, riparian areas, and a 5,272-acre cultural designation does not constitute a significant action. The agency should include the FONSI in this document and provide a public comment period before it is finalized.

  A hole PLAN found in the agency’s own analysis