Stop the elimination of public objection rights for this 4,242-acre Oregon fuel break
Southwest Tiller Fuel Break Project
U.S. Forest Service· Tiller Ranger District, Umpqua 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 Oregon
Predicted likely to care is a guess from footprint in Oregon, by the same match the STAND matchmaker runs, with no link to this decision. Give straight to them; nothing routes through us.
- Cascadia Wildlands
Predicted likely to care · a guess
Works Oregon: plaintiff in the January 2026 suit against the Roseburg BLM plan to log nearly 7,000 acres near Camas Valley.
- Crag Law Center
Predicted likely to care · a guess
Works Oregon: represented Bird Alliance of Oregon, the Center for Biological Diversity, and Cascadia Wildlands in the 2012 Endangered Species Act suit over logging occupied murrelet habitat, which ended in the 2014 settlement canceling 28 timber sales.
- Oregon Natural Desert Association
Predicted likely to care · a guess
Works Oregon: anchors the McDermitt Caldera Coalition on the Oregon side and fought the BLM's December 2025 approval of the Jindalee/HiTech lithium exploration project through the permitting process.
- Oregon Wild
Predicted likely to care · a guess
Works Oregon: its attorneys, with Cascadia Wildlands and Crag Law Center, represent the groups challenging BLM's Blue and Gold old-growth logging project in the Coast Range.
Every group above is on STAND for Public Lands, with its court record, its filings and who backs it.
The agency is proposing to thin 4,242 acres of plantation, burn over 13,600 acres, and build 4 miles of new roads while invoking emergency authority to eliminate the public's right to object before the decision is final.
What’s at risk
Approximately 850 acres of Riparian Reserves, 4 miles of new temporary roads near streams, and 20 stream culvert replacements put fish habitat and downstream water quality at risk with no site-specific aquatic analysis yet completed. Late Successional Reserve units and Northern Spotted Owl Activity Centers are proposed for commercial harvest with no Northwest Forest Plan consistency analysis disclosed.
If this goes through
If the decision issues under the Emergency Action Determination, the public loses pre-decisional review rights and the project can move to implementation as soon as summer 2026 across multiple townships in Douglas and Jackson Counties. Ongoing maintenance burning commits the landscape to a recurring prescribed fire program of undefined frequency and cumulative extent with no long-term effects analysis completed.
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
- Plantation thinning area proposed for treatment
- approximately 4,242 acres
- Miles of shaded fuel break (PODs) proposed
- approximately 35 miles
- Additional underburning acres outside treatment units
- approximately 4,500 acres
- New temporary road construction proposed
- 4 miles new construction
- Acres treated within Riparian Reserves
- approximately 850 acres
- Post-treatment prescribed fire acreage total
- approximately 9,100 acres
Proposed Action
Open the document ↗“Creation and maintenance of potential operational delineations (PODs) utilizing shaded fuel breaks along approximately 35 miles”
Proposed Action
Open the document ↗“Approximately 4,500 additional acres of underburning is planned outside of plantation thinning and fuels reduction treatment units.”
Culvert Replacement, Road Maintenance, Temporary Roads, and Reconstruction
Open the document ↗“Approximately 22 miles of the proposed temporary roads will utilize and reconstruct existing roadbeds, and 4 miles would be new construction.”
Treatment in Riparian Reserves
Open the document ↗“Approximately 850 acres would be treated within riparian reserves (RRs).”
Prescribed Fire
Open the document ↗“Prescribed fire would be completed to treat post-treatment activity fuels (covering, in total, approximately 9,100 acres)”
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
The Forest Service wants to thin about 4,242 acres of plantations, build shaded fuel breaks along about 35 miles of roads, reduce fuels and burn across the southwest Tiller area. It says this area faces the greatest wildfire threat to homes and access roads on the district. It also plans to use an emergency authority that would remove pre-decisional objections.
“This area includes the highest concentrations of private lands, homes and structures, and critical access roads across the district and has the greatest need for active management to prepare for future fires.”
Project Purpose of and Need for 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.
Purpose and need
No support given
The Forest used modeling to prioritize the upper Cow Creek Basin, and it says the area has the district's highest concentrations of private lands, homes and structures, and critical access roads, and the greatest need for active management.
The background section describes a district-wide analysis. It used fire behavior modeling under 90th percentile weather, a wildland-urban interface map and a suppression difficulty index, and Figure 1 maps the result. But the text gives no counts of homes or structures, no modeled fire severity and no comparison with other parts of the district.
AskPublish the modeling results, including counts of homes and structures and the modeled fire severity, and compare this area with the rest of the district.
The agency’s words, the record +Hide the words
The agency says
“Through IFTDSS modeling, the Forest prioritized the upper Cow Creek Basin / southwest Tiller project area. This area includes the highest concentrations of private lands, homes and structures, and critical access roads across the district and has the greatest need for active management to prepare for future fires.”
Project Purpose of and Need for Action
Elsewhere in the same document
“A district-wide analysis was conducted using fire behavior modeling for 90th percentile weather conditions, district Wildland-Urban Interface (WUI) map and the national Suppression Difficulty Index map which identified Upper Cow Creek as a top priority (Figure 1).”
Background Information
Effects
No support given
Shaded fuel breaks and thinning will reduce fire intensity, give firefighters safe anchor points and reduce catastrophic wildfire risk on federal and nearby lands.
The notice explains how the treatments are meant to work. Shaded fuel breaks would thin to make space between tree crowns, cut ground and ladder fuels, and keep a minimum 40% canopy cover. It says this limits surface fuels and lowers the potential for crown fire. Plantations would go from an average of 190 trees per acre to an average of 50-80 trees per acre. Fuel breaks would extend up to 75 feet from each side of the road in stands less than 80 years old and up to 150 feet in stands greater than 80 years old. But the notice gives no modeled flame lengths or crown fire potential before and after treatment, and it cites no study.
AskShow modeled fire behavior before and after treatment for the fuel breaks, and say how often they'll need maintenance to stay effective as brush grows back.
The agency’s words, the record +Hide the words
The agency says
“These treatments reduce fireline intensity providing firefighters safe and effective anchor points to suppress and manage large fires and reduce the risk of catastrophic wildfire on both federal and adjacent lands.”
Background Information
Elsewhere in the same document
“Where PODS intersect plantation thinning units, the thinning prescription may be modified to maintain a residual canopy cover of approximately 40% or greater to limit brush growth after treatment.”
Plantation Thinning
Effects
No support given
Treatments on approximately 850 acres in riparian reserves are designed to restore and maintain the ecological health of watersheds and aquatic ecosystems.
Table 2 sets stream buffers. For plantation thinning they're 120 feet on each side of perennial fish streams. For fuels treatments they're 50 feet on streams with anadromous fish and 25 feet on intermittent or ephemeral streams. The notice says reserves outside the buffers would be thinned only where it helps meet aquatic conservation and fuels objectives. It also lists examples of riparian design features: limits on equipment use and temporary road construction in sensitive areas, and requirements for erosion control and shade protection. But those design features haven't been developed yet, and the notice doesn't analyze effects on shade, sediment or stream temperature.
AskExplain why the 25 to 50 foot fuels buffers protect fish-bearing streams. Publish the riparian project design features and an analysis of effects on shade and sediment.
The agency’s words, the record and the law +Hide the words
The agency says
“All treatments inside RRs are designed to restore and maintain the ecological health of watershed and aquatic ecosystems through the Aquatic Conservation Strategy Objectives (ACSO; NWFP pp. C-30 to 38).”
Treatment in Riparian Reserves
Elsewhere in the same document
“Project Design Features (PDFs) will be developed to prevent and minimize impacts to forest resources, and for water quality protection.”
Apply Project Design Features and best management practices
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) ↗
Show 3 more claims +Show fewer
Effects
No support given
Road maintenance and reconstruction, including culvert replacement, will improve watershed conditions.
The notice identifies approximately 20 stream culverts for replacement. It says many were installed too small for a 100-year flood, which is today's standard, and most will be made larger. That supports the watershed benefit of the culvert work. Approximately 22 miles of reconstructed and 4 miles of new temporary road are a separate effect that this claim doesn't weigh.
The agency’s words, the record +Hide the words
The agency says
“Maintenance and reconstruction of system roads in the project area is needed to improve watershed conditions and to allow for project related haul.”
Culvert Replacement, Road Maintenance, Temporary Roads, and Reconstruction
Elsewhere in the same document
“Most will be upsized since many culverts installed in the past were not large enough to accommodate a 100-year flood which is today’s standard.”
Culvert Replacement, Road Maintenance, Temporary Roads, and Reconstruction
Science
No support given
A century of fire exclusion and changed management has pushed forests far from historical conditions and raised the risk of harmful fire.
The notice says these lands historically had mixed severity fire. But it gives no historical fire return intervals, no measure of how far conditions have departed and no fuel loading figures. Maintenance burning is supposed to match historic fire return intervals, yet those intervals are never stated.
AskState the historical fire return intervals and current fuel loadings for these stands, and give their sources.
The agency’s words, the record and the law +Hide the words
The agency says
“However, over the course of a century, fire exclusion and changes to forest management have created large departures from historical vegetation patterns and increased the potential for adverse fire effects.”
Project Purpose of and Need for Action
Elsewhere in the same document
“The proposed actions also include the implementation of maintenance burning to maintain the alignment with historic fire return intervals to ensure fuels accumulations do not reach or exceed the extent to which they are seen today, overall increasing stand resiliency into the future.”
Prescribed Fire
The law
“ensure the professional integrity, including scientific integrity, of the discussion and analysis in an environmental document; (E) make use of reliable data and resources in carrying out this chapter;” National Environmental Policy Act, 42 U.S.C. 4332(2)(D)-(E) ↗
Process
No support given
Closing Forest System Road 3242-201 to the public is needed to restrict access to the new weather station.
The purpose and need section says actions are needed to protect the weather station and restrict access to it for fire-related and ongoing forest management needs. The notice also cites a project-level travel analysis. But it doesn't describe any threat to the station that requires closing the road to the public. It also gives two lengths for the closure: approximately 1.5 miles in the proposed action and approximately 0.25 miles in the transportation section.
AskGive the correct length of the Road 3242-201 closure, explain why public access must be blocked, and consider protecting just the station site instead.
The agency’s words, the record +Hide the words
The agency says
“This the sole route to the Red Apple RAWS station and this action is needed to restrict access to this location.”
Transportation System Changes
Elsewhere in the same document
“Change of Forest System Road 3242-201 (approximately 1.5 miles) from Road Open to all Vehicles to Road Closed for all vehicles except for administrative use only.”
Proposed Action
Read from the agency’s own decision document ↗, all 14 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 oppose this action as proposed, and I ask the agency to weigh the specific harms below.
- The document invokes an Emergency Action Determination (EAD) under IIJA section 40807 to eliminate pre-decisional administrative review and limit the EA to only a proposed action and no-action alternative. However, the document provides no factual basis, finding, or declaration that an emergency actually exists at this site. The background section describes a long-term fuels buildup 'over the course of a century' and states actions 'would be planned to initiate as soon as summer, 2026,' which is inconsistent with emergency conditions requiring abbreviated NEPA. The agency should justify in writing, with specific findings, why a multi-year fuels accumulation problem that will not be addressed until 2026 at the earliest qualifies as an emergency warranting elimination of public objection rights, or withdraw the EAD designation and conduct a standard EA with pre-decisional review.
- The document proposes treating approximately 9,100 acres with post-treatment prescribed fire and 4,500 additional acres of underburning outside treatment units, yet provides no air quality analysis, no smoke modeling, no discussion of cumulative smoke impacts on nearby residents or communities, and no identification of which airsheds or air quality standards apply. The only reference to air quality is a single sentence stating burns 'will follow all local air quality standards and guidelines,' with no analysis of whether those standards can actually be met given the scale of burning. The agency should prepare a site-specific air quality and smoke impact analysis before finalizing the EA, including modeling of PM2.5 impacts on communities near the project area.
- The document identifies approximately 850 acres of treatment within Riparian Reserves and states all treatments are designed to meet Aquatic Conservation Strategy Objectives (ACSO), but provides no site-specific analysis of how thinning inside riparian reserves will affect water temperature, sediment delivery, large wood recruitment, or fish habitat. The document also proposes replacing approximately 20 stream culverts and constructing 4 miles of new temporary roads, both of which directly affect streams, yet no quantitative watershed or aquatic effects analysis is presented in this scoping document. The agency should complete and disclose a watershed condition analysis and demonstrate ACSO consistency before the EA is finalized.
- The document proposes 4 miles of new temporary road construction and approximately 22 miles of reconstruction of existing roadbeds, plus use and potential blasting at five named rock quarries, but provides no analysis of erosion risk, sediment delivery to streams, or impacts to the sensitive granitic and schistose soils the document itself flags as requiring special care. The document simply states soil mass movement potential 'will be evaluated' in the future, deferring the core analysis to post-decision implementation. Deferring this analysis until after the decision is made violates the requirement that environmental consequences be analyzed before the decision. The agency should complete slope stability and erosion risk analysis for all temporary road segments and quarry sites before the EA decision is issued.
Show every point from the document
- The document lists Late Successional Reserves (LSR) and LSR in Northern Spotted Owl Activity Centers as land use allocations within the project area, and Table 1 shows multiple plantation thinning units inside LSR. However, the document contains no analysis of whether proposed plantation thinning within LSR and Northern Spotted Owl Activity Centers is consistent with Northwest Forest Plan standards, which require that management in LSR move conditions toward late-successional forest. The document states only that LSR prescriptions will 'focus on low residual density, uneven spacing, leaving trees with large limbs, broken tops, etc. for wildlife,' with no demonstration that commercial harvest of merchantable trees in LSR meets the legal standard. The agency should provide a specific Northwest Forest Plan consistency analysis for all LSR units before finalizing the EA.
- The document states the scoping comment period runs from June 17 through July 6, 2025, a window of only 19 days. At the same time, the document invokes emergency authority to eliminate pre-decisional administrative review, meaning this scoping period is the primary and potentially only formal public participation opportunity before a decision is issued. A 19-day window is inadequate for a project covering multiple townships across Douglas and Jackson Counties with 4,242 acres of plantation thinning, 35 miles of fuel breaks, 4 miles of new roads, and prescribed fire on over 13,000 acres. The agency should extend the scoping period to at least 45 days to allow meaningful participation from all affected communities, Tribes, and resource specialists.
- The document identifies the Cow Creek Band of Umpqua Tribe of Indians (CCBUTI) as a collaborating partner and names the Cow Creek Gorge Special Interest Area as requiring modified treatment, but provides no government-to-government tribal consultation analysis, no identification of traditional cultural properties or sacred sites, no Section 106 National Historic Preservation Act compliance discussion, and no assessment of project impacts on tribal cultural resources across the full project area. Collaboration in a planning meeting is not a substitute for formal tribal consultation. The agency should document its government-to-government consultation with CCBUTI and complete a cultural resources inventory and Section 106 compliance review before finalizing the EA.
- The document proposes underburning on approximately 4,500 acres outside of plantation thinning and fuels reduction units and states maintenance burns will be used to maintain alignment with historic fire return intervals into the future, but provides no analysis of how frequently maintenance burns will recur, what cumulative acreage will be burned over time, or what the long-term effects of repeated prescribed fire on soil, vegetation, and wildlife will be. The commitment to ongoing maintenance burning represents a long-term management regime that NEPA requires be analyzed in terms of its cumulative and long-term effects, not just the initial treatment. The agency should analyze the frequency, extent, and cumulative environmental effects of the proposed maintenance burning program in the EA.
- The document proposes thinning plantations from an average density of 190 trees per acre to 50 to 80 trees per acre across approximately 4,242 acres, generating large volumes of merchantable timber to be sold and removed, but provides no estimate of timber volume, no economic analysis, no discussion of haul truck traffic on County Road 36 or Forest System roads, and no noise or road safety impact analysis for nearby residents. The document acknowledges dust abatement 'could also occur as needed as haul occurs,' which implies significant truck traffic, but does not quantify it. The agency should disclose estimated timber volume, number of truck trips, haul routes, and traffic and road safety impacts in the EA before the decision is made.
- The document states that the project includes Unit 101 at 469 acres, the single largest unit, designated for both ground-based and cable logging, but the logging system for several units including Units 37, 45, and 47 is listed as 'Unknown' in Table 1. Logging system selection directly determines ground disturbance, erosion risk, and feasibility on steep terrain, and the document itself acknowledges that terrain and soil conditions inform the designated system. Leaving the logging system unspecified for named units at the scoping stage means the public cannot meaningfully evaluate the environmental consequences of those units. The agency should determine and disclose the logging system for all units, including those currently listed as Unknown, before the EA is finalized.
- 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
4051 ac commercial thinning in stands under 80 years old, 2398 ac noncomm thinning, 10481 ac prescribed burning would contribute to roadside shaded fuelbreak PODs along 82 road miles. Administrative site prep for new Remote Access Weather Station with closure of 2.2 mi roads. 40 culvert improvements
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 document invokes an Emergency Action Determination (EAD) under IIJA section 40807 to eliminate pre-decisional administrative review and limit the EA to only a proposed action and no-action alterna
The document invokes an Emergency Action Determination (EAD) under IIJA section 40807 to eliminate pre-decisional administrative review and limit the EA to only a proposed action and no-action alternative. However, the document provides no factual basis, finding, or declaration that an emergency actually exists at this site. The background section describes a long-term fuels buildup 'over the course of a century' and states actions 'would be planned to initiate as soon as summer, 2026,' which is inconsistent with emergency conditions requiring abbreviated NEPA. The agency should justify in writing, with specific findings, why a multi-year fuels accumulation problem that will not be addressed until 2026 at the earliest qualifies as an emergency warranting elimination of public objection rights, or withdraw the EAD designation and conduct a standard EA with pre-decisional review.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe document proposes treating approximately 9,100 acres with post-treatment prescribed fire and 4,500 additional acres of underburning outside treatment units, yet provides no air quality analysis, n
The document proposes treating approximately 9,100 acres with post-treatment prescribed fire and 4,500 additional acres of underburning outside treatment units, yet provides no air quality analysis, no smoke modeling, no discussion of cumulative smoke impacts on nearby residents or communities, and no identification of which airsheds or air quality standards apply. The only reference to air quality is a single sentence stating burns 'will follow all local air quality standards and guidelines,' with no analysis of whether those standards can actually be met given the scale of burning. The agency should prepare a site-specific air quality and smoke impact analysis before finalizing the EA, including modeling of PM2.5 impacts on communities near the project area.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe document identifies approximately 850 acres of treatment within Riparian Reserves and states all treatments are designed to meet Aquatic Conservation Strategy Objectives (ACSO), but provides no si
The document identifies approximately 850 acres of treatment within Riparian Reserves and states all treatments are designed to meet Aquatic Conservation Strategy Objectives (ACSO), but provides no site-specific analysis of how thinning inside riparian reserves will affect water temperature, sediment delivery, large wood recruitment, or fish habitat. The document also proposes replacing approximately 20 stream culverts and constructing 4 miles of new temporary roads, both of which directly affect streams, yet no quantitative watershed or aquatic effects analysis is presented in this scoping document. The agency should complete and disclose a watershed condition analysis and demonstrate ACSO consistency before the EA is finalized.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe document proposes 4 miles of new temporary road construction and approximately 22 miles of reconstruction of existing roadbeds, plus use and potential blasting at five named rock quarries, but pro
The document proposes 4 miles of new temporary road construction and approximately 22 miles of reconstruction of existing roadbeds, plus use and potential blasting at five named rock quarries, but provides no analysis of erosion risk, sediment delivery to streams, or impacts to the sensitive granitic and schistose soils the document itself flags as requiring special care. The document simply states soil mass movement potential 'will be evaluated' in the future, deferring the core analysis to post-decision implementation. Deferring this analysis until after the decision is made violates the requirement that environmental consequences be analyzed before the decision. The agency should complete slope stability and erosion risk analysis for all temporary road segments and quarry sites before the EA decision is issued.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe document lists Late Successional Reserves (LSR) and LSR in Northern Spotted Owl Activity Centers as land use allocations within the project area, and Table 1 shows multiple plantation thinning uni
The document lists Late Successional Reserves (LSR) and LSR in Northern Spotted Owl Activity Centers as land use allocations within the project area, and Table 1 shows multiple plantation thinning units inside LSR. However, the document contains no analysis of whether proposed plantation thinning within LSR and Northern Spotted Owl Activity Centers is consistent with Northwest Forest Plan standards, which require that management in LSR move conditions toward late-successional forest. The document states only that LSR prescriptions will 'focus on low residual density, uneven spacing, leaving trees with large limbs, broken tops, etc. for wildlife,' with no demonstration that commercial harvest of merchantable trees in LSR meets the legal standard. The agency should provide a specific Northwest Forest Plan consistency analysis for all LSR units before finalizing the EA.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe document states the scoping comment period runs from June 17 through July 6, 2025, a window of only 19 days.
The document states the scoping comment period runs from June 17 through July 6, 2025, a window of only 19 days. At the same time, the document invokes emergency authority to eliminate pre-decisional administrative review, meaning this scoping period is the primary and potentially only formal public participation opportunity before a decision is issued. A 19-day window is inadequate for a project covering multiple townships across Douglas and Jackson Counties with 4,242 acres of plantation thinning, 35 miles of fuel breaks, 4 miles of new roads, and prescribed fire on over 13,000 acres. The agency should extend the scoping period to at least 45 days to allow meaningful participation from all affected communities, Tribes, and resource specialists.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe document identifies the Cow Creek Band of Umpqua Tribe of Indians (CCBUTI) as a collaborating partner and names the Cow Creek Gorge Special Interest Area as requiring modified treatment, but provi
The document identifies the Cow Creek Band of Umpqua Tribe of Indians (CCBUTI) as a collaborating partner and names the Cow Creek Gorge Special Interest Area as requiring modified treatment, but provides no government-to-government tribal consultation analysis, no identification of traditional cultural properties or sacred sites, no Section 106 National Historic Preservation Act compliance discussion, and no assessment of project impacts on tribal cultural resources across the full project area. Collaboration in a planning meeting is not a substitute for formal tribal consultation. The agency should document its government-to-government consultation with CCBUTI and complete a cultural resources inventory and Section 106 compliance review before finalizing the EA.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe document proposes underburning on approximately 4,500 acres outside of plantation thinning and fuels reduction units and states maintenance burns will be used to maintain alignment with historic f
The document proposes underburning on approximately 4,500 acres outside of plantation thinning and fuels reduction units and states maintenance burns will be used to maintain alignment with historic fire return intervals into the future, but provides no analysis of how frequently maintenance burns will recur, what cumulative acreage will be burned over time, or what the long-term effects of repeated prescribed fire on soil, vegetation, and wildlife will be. The commitment to ongoing maintenance burning represents a long-term management regime that NEPA requires be analyzed in terms of its cumulative and long-term effects, not just the initial treatment. The agency should analyze the frequency, extent, and cumulative environmental effects of the proposed maintenance burning program in the EA.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe document proposes thinning plantations from an average density of 190 trees per acre to 50 to 80 trees per acre across approximately 4,242 acres, generating large volumes of merchantable timber to
The document proposes thinning plantations from an average density of 190 trees per acre to 50 to 80 trees per acre across approximately 4,242 acres, generating large volumes of merchantable timber to be sold and removed, but provides no estimate of timber volume, no economic analysis, no discussion of haul truck traffic on County Road 36 or Forest System roads, and no noise or road safety impact analysis for nearby residents. The document acknowledges dust abatement 'could also occur as needed as haul occurs,' which implies significant truck traffic, but does not quantify it. The agency should disclose estimated timber volume, number of truck trips, haul routes, and traffic and road safety impacts in the EA before the decision is made.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe document states that the project includes Unit 101 at 469 acres, the single largest unit, designated for both ground-based and cable logging, but the logging system for several units including Uni
The document states that the project includes Unit 101 at 469 acres, the single largest unit, designated for both ground-based and cable logging, but the logging system for several units including Units 37, 45, and 47 is listed as 'Unknown' in Table 1. Logging system selection directly determines ground disturbance, erosion risk, and feasibility on steep terrain, and the document itself acknowledges that terrain and soil conditions inform the designated system. Leaving the logging system unspecified for named units at the scoping stage means the public cannot meaningfully evaluate the environmental consequences of those units. The agency should determine and disclose the logging system for all units, including those currently listed as Unknown, before the EA is finalized.
A hole PLAN found in the agency’s own analysis, quote verified against the document
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