Stop 190 MMBF harvest in a Chinook-impaired Oregon watershed
Fall Creek
U.S. Forest Service· Willamette National Forest, Middle Fork Ranger DistrictU.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 proposes to log 11,906 acres and haul 190 million board feet over 325 miles of road in a watershed where three streams are already listed as temperature-impaired and pre-spawn mortality of threatened Spring Chinook salmon averages 65 percent annually.
What’s at risk
Fall Creek and two tributaries are listed under the Clean Water Act for year-round temperature impairment and impaired fish and aquatic life. Sixty-three northern spotted owl home ranges overlap the project area and most are already impaired by recent fires. The agency's own fish analysis rates the project as likely to adversely affect Spring Chinook salmon and its critical habitat.
If this goes through
Up to 20 timber sales would be offered over at least five years, with harvesting extending over roughly a decade. Wet-season log haul on 292 miles of aggregate-surfaced roads would occur while the new TMDL implementation plan for these temperature-impaired streams remains unwritten, leaving no enforceable compliance standard in place during the period of greatest sediment risk.
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 commercial thinning area proposed
- 11,906 acres
- Miles of road proposed for log haul and maintenance
- 325 miles
- New temporary road construction proposed
- 16.5 miles new, 4.5 miles existing template
- Average annual pre-spawn mortality, Spring Chinook, Fall Creek
- approximately 65% annually
- Late-Successional Reserve acres proposed for thinning
- 8,649 acres
Table 1 - Summary of Proposed Actions
Open the document ↗“Commercial Thinning Harvest – Total treatment area 11,906 acres”
Table 1 - Summary of Proposed Actions
Open the document ↗“Haul Route Maintenance and Reconstruction 325 miles”
Table 1 - Summary of Proposed Actions
Open the document ↗“Temporary Roads - New 16.5 miles Temporary Roads – Existing template 4.5 miles”
Would log haul and associated roadwork cause in-stream sediment concentrations to increase beyond levels that are harmful to fish or water quality?
Open the document ↗“Pre-spawn mortality in Fall Creek is also high, averaging about 65% annually.”
Table 1 - Summary of Proposed Actions
Open the document ↗“Late-Successional Reserve Thinning 8,649 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
- 2
- Hold up
- 6
- No support given
- 2
- Never analyzed
The Forest Service wants to commercially thin about 11,906 acres of 42- to 79-year-old managed stands in the Fall Creek watershed and sell about 190 million board feet of timber. The project also includes road work and stream restoration. The agency says the stands are overcrowded and that thinning would speed old-forest structure, improve riparian areas and support local timber jobs.
“The Middle Fork Ranger District of the Willamette National Forest is proposing to improve forest stand conditions and provide forest products to the local economy.”
Introduction
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 project is exempt from Survey and Manage pre-disturbance surveys because it proposes only young-stand thinning and riparian and stream improvement.
The court's exemption covers thinning in stands younger than 80 years and certain riparian and stream improvement projects. These stands are 42 to 79 years old, so the thinning fits, and the document treats temporary roads, road work and quarry use as connected actions of the thinning. But the project includes about 21 miles of temporary roads, two quarry expansions totaling 1.83 acres with clearing and grubbing, and possible road re-alignment. The document doesn't explain why those fall within the exemption.
AskExplain whether the quarry expansions, temporary roads and road re-alignment fall under the thinning exemption, or survey for Survey and Manage species where those activities disturb habitat.
The agency’s words, the record and the law +Hide the words
The agency says
“As this project proposes only these activities, it is exempted from the Survey and Manage standards and guidelines.”
Survey and Manage
Elsewhere in the same document
“Expansion is being proposed in two quarries with the expansions totaling 1.83 acres.”
Road Maintenance and Reconstruction
“Construction of approximately 21 miles of new temporary spur roads would be required to access timber harvest units.”
Temporary Road Construction
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) ↗
Alternatives
No support given
The agency rejected an alternative with no riparian harvest partly because thinning would reduce the elevated risk of future disturbance in overstocked riparian stands.
The document says untreated riparian stands would face a growing risk of loss to fire, insects and disease, which spread more easily through dense, uniform stands. It says thinning lowers canopy bulk density, raises canopy base height and grows thicker-barked trees over the medium term of 15 to 30 years (Agee and Skinner 2005; Dunn and Bailey 2016). Appendix C says thinning and fuels work would help protect streams from high-severity fire. But the agency's own modeling found mostly low to moderate fire behavior before treatment and minimal effect from thinning, with 1% of units showing passive crown fire both before and after. Harvest also raises surface fuels for 1 to 5 years until those fuels are treated, and the document gives no insect or disease data.
AskReconcile the disturbance-risk reason for rejecting the no-riparian-harvest alternative with the fire modeling, or analyze that alternative in detail.
The agency’s words, the record and the law +Hide the words
The agency says
“Recent wildfires have substantially altered conditions within Riparian Reserves throughout the project area, however many Riparian Reserve stands proposed for treatment are still overstocked, homogenous, and would benefit from treatment to reduce elevated risk for future disturbance.”
Alternative that Does Not Allow Harvest in Riparian Reserves
Elsewhere in the same document
“This indicates that commercial thinning would have minimal effect on fire behavior in the stands within the project area, under the weather conditions that were modeled seen in Table 5.”
How would commercial thinning harvest influence fire behavior in stands?
“The result of modeling done in IFTDSS shows 1% of the proposed commercial thinning units could have passive crown fire both pre and post treatment, as seen in Figure 3.”
How would commercial thinning harvest influence fire behavior in stands?
The law
“consistent with the provisions of this chapter, study, develop, and describe technically and economically feasible alternatives;” National Environmental Policy Act, 42 U.S.C. 4332(2)(F) ↗
Effects
No support given
Sediment from wet-weather log haul would harm streams only in the short term and poses no significant long-term risk once design features are applied.
The document says maintaining roads before haul, surfacing them with high-quality rock and adding cross drains near streams would reduce fine sediment (Luce and Danehy 2022). It says haul would stop when sediment is seen moving into ditches or streams. It also argues that a maintained road system lowers the risk of large road failures compared with taking no action. But it gives no sediment estimates and relies on professional experience with design features. It calls greater fine sediment delivery from road work probable. Most of the haul route is proposed for year-round haul, and the same routes would be used every year over the life of the project. It says sediment may stay in a stream reach for multiple years, and it rates spring Chinook salmon as likely to be adversely affected.
AskEstimate how much sediment wet-season haul would deliver over the roughly decade-long haul period. Explain why haul near Chinook critical habitat isn't limited to the dry season.
The agency’s words, the record and the law +Hide the words
The agency says
“In summary, wet-weather haul can affect water quality and aquatic resources in the short-term by increasing sediment delivery to streams. However, it is unlikely to pose a significant risk over the long-term with proper administration of PDFs and BMPs.”
Effects of Sedimentation Associated with Log haul
Elsewhere in the same document
“It is probable that the proposed road maintenance and reconstruction, especially on freshly constructed and maintained aggregate surfaced roads, would result in greater amounts of fine sediment delivery to the stream network.”
Effects of sedimentation from road reconstruction and maintenance
“Many of the same haul routes will be used annually and by multiple timber purchasers over the life of the project.”
Spatial and Temporal Bounds of Analysis
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) ↗
Show 3 more claims +Show fewer
Effects
No support given
Surveys before and during logging would keep the project from causing incidental take of northern spotted owls.
Design features require protocol surveys before and during implementation. They drop or modify downgrade thinning in occupied territories, keep thinning out of occupied nest patches and all known Late-Successional Reserve nest patches, and require a new review if surveys find activity centers that have moved or are new. The document ties this to the 2023 programmatic biological assessment and Biological Opinion. But its own methodology says substantial thinning that maintains but degrades foraging habitat in a core area below 50% suitable can impair a territory, and 10 Late-Successional Reserve stands overlap impaired core areas. The design feature that drops thinning in occupied, impaired territories covers only removing or downgrading habitat. The document doesn't say what happens in those 10 stands if owls are found.
AskExplain how the 10 Late-Successional Reserve stands in impaired core areas avoid the impairment the methodology describes. Confirm that new surveys will replace the 1990s owl site locations before any sale.
The agency’s words, the record +Hide the words
The agency says
“Because surveys would be performed to ensure occupied territories and nest patches are not impaired, there should be no incidental take of northern spotted owls from the proposed action.”
How would loss of canopy cover from vegetation management impact northern spotted owl or their habitat?
Elsewhere in the same document
“Impairment of territories can also occur from thinning that reduces cover, snags, and down logs in nest patches and from substantial thinning that maintains but degrades foraging habitat in a core area below the 50% suitable threshold level.”
Methodology
“Within the LSR, 10 stands overlap impaired core areas that are proposed to be thinned to maintain canopy cover at levels greater than 60%.”
Table 12
Effects
No support given
No-harvest buffers would protect stream shade, so the project wouldn't worsen temperatures in streams already impaired for temperature.
Appendix C says the no-harvest buffers would maintain the primary and secondary shade zones and that temperature effects would be negligible. Buffers run 30 to 120 feet depending on stream class. Outer reserves keep at least 40% canopy cover and 60 trees per acre, gaps stay more than 172 feet from streams, and fall-and-leave areas keep 70% canopy cover. The Forest says it will follow the 2008 Willamette Basin Water Quality Restoration Plan and the 2012 Northwest Forest Plan temperature strategies until its new plan is finished. But the text has no shade or temperature analysis for Fall Creek, Hehe Creek or Portland Creek, all listed as temperature impaired. Thinning is also allowed between the buffers and 172 feet, the zone the document treats as secondary shade.
AskProvide a stream shade and temperature analysis for Fall Creek, Hehe Creek and Portland Creek, including thinning between the no-harvest buffers and 172 feet.
The agency’s words, the record and the law +Hide the words
The agency says
“Primary stream shade zones, wood recruitment, and sediment buffering functions within stands would be protected by no-harvest buffers.”
Commercial Thinning Harvest and Connected Activities
Elsewhere in the same document
“All of these water bodies are listed for year-round temperature impairment and impaired fish and aquatic life beneficial uses (ODEQ Integrated Report, 2022).”
Clean Water Act
“Returning adult salmon rely on deep cool pools along the Fall Creek mainstem for pre-spawn staging and for survival during warm summer months.”
Status of Fisheries Resources
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) ↗
Economics
No support given
The 190 million board feet would equal about 19% of annual local mill capacity.
The arithmetic works: 190 divided by the 1,000 million board feet working capacity is 19%, and about 11 jobs per million board feet gives about 2,090 jobs. The 1,000 figure is the agency's working estimate. It's based on about 1,400 million board feet of capacity in 2008 (Gale et al. 2012), and the document notes that no updated capacity report exists. Readers should know that 190 million board feet is the whole project's volume, harvested over about a decade, so its share of any single year's capacity would be smaller.
AskRestate the volume as a yearly share of mill capacity based on the actual sale and harvest schedule. Give a source for the 1,000 million board feet working capacity.
The agency’s words, the record +Hide the words
The agency says
“The 190 MMBF represents about 19% of annual local mill capacity and provides raw material that supports local jobs while reducing reliance on imported logs and associated costs.”
How would the timber volume generated by the proposed action contribute to the local economy?
Elsewhere in the same document
“Because this volume could be sold over roughly five years and harvested three to five years later, the economic contribution could extend over about a decade.”
How would the timber volume generated by the proposed action contribute to the local economy?
“For this analysis, a working capacity estimate of 1,000 MMBF is used to gauge how the proposed action contributes to local market demand.”
Potentially Affected Environment
What the document never analyzes
Not analyzed
Deer and elk habitat
The project would thin about 11,906 acres, open gaps, build about 21 miles of temporary roads and haul on 325 miles of road across a 62,071-acre area. The document never addresses forage, cover or disturbance for game animals.
Searched all 112 pages for ‘deer’, ‘big game’, ‘winter range’. None appear.
AskAnalyze how thinning, gaps, roads and haul would affect deer and elk forage, hiding cover and disturbance in the project area.
Not analyzed
Downstream drinking water uses
Fall Creek drains to Fall Creek dam. The document expects more fine sediment during wet-season haul and lists streams as temperature impaired, but it never says whether anyone downstream relies on this water.
Searched all 112 pages for ‘drinking water’, ‘municipal’, ‘water supply’, ‘domestic water’. None appear.
AskIdentify any downstream drinking water uses of Fall Creek and assess how haul sediment and roadwork could affect them.
Where its own record backs the agency
Purpose and needMost of the proposed stands are overcrowded young plantations, and variable density thinning would improve their growth and diversity.Why it holds +
Table 3 puts the average stand density index at 416 against a maximum of 595, or about 70 percent. That's above the 60 percent self-thinning level the document cites. Modeling shows 42% faster diameter growth after thinning. The document also admits that without action, snags and down wood would develop on more acres.
The agency says
“About 85% of the stands have SDI’s 60% or greater of SDI max with the remaining expected to reach that threshold within ten years if left untreated.”
How would variable density thinning affect stand growth, diversity and structure?
Its own record backs it
“Using FVS, modelling shows that in these stands overstory tree diameter growth in the first decade following thinning averages 42% higher than no thinning.”
How would variable density thinning affect stand growth, diversity and structure?
“That increased growth continues over time with tree diameter growth still being about 39% higher by 2056.”
How would variable density thinning affect stand growth, diversity and structure?
ScienceCarbon removed by the thinning would be too small to matter at the scale of the whole forest.Why it holds +
511,958 megagrams is about 0.51 teragrams, or roughly 0.19% of 276 teragrams. That's within the 11.1 teragram margin of error. The document's own per-hectare formula (1.81 times 712,501, divided by 21,850) gives about 59 megagrams, not the 107 it reports. A smaller figure would shrink the estimate further, so the conclusion still holds.
The agency says
“This upper-bounds estimate of carbon removed represents less than 0.19% of the total of 276 Tg stored by the Forest as of 2023.”
What impact will commercial thinning harvest have on biogenic carbon stores?
Its own record backs it
“Assuming 11,906acres of thinning, the upper-bounds amount of carbon taken off-site with the proposed action would be around 511,958 Mg (11,906acres x 43 Mg of carbon removed per acre).”
What impact will commercial thinning harvest have on biogenic carbon stores?
“To calculate carbon removed per hectare harvested, we multiple 1.81 by 712,501 and divide the result by 21,850.”
What impact will commercial thinning harvest have on biogenic carbon stores?
Read from the agency’s own decision document ↗, all 112 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 EA dismisses a no-temporary-road alternative by citing cost and feasibility, but the fire behavior analysis itself admits that immediately after harvest, before fuels treatments are complete, surface fuel loading increases and fire risk rises. The EA provides no estimate of how long the 21 miles of new temporary roads would remain on the landscape before rehabilitation is complete, nor does it analyze the sediment risk during that window. Section 'Alternative that Included No Temporary Road Construction' eliminates the alternative primarily on economic grounds without quantifying the sediment and fire-risk tradeoff during the post-harvest, pre-treatment interval. The agency should prepare a quantitative risk analysis comparing temporary road sediment delivery against the no-road scenario before finalizing any decision.
- The EA acknowledges that Fall Creek, Hehe Creek, and Portland Creek are already listed as impaired under Clean Water Act Section 303(d) for year-round temperature, and that pre-spawn mortality of Spring Chinook salmon averages about 65 percent annually. Despite this, the sediment analysis concludes that log haul on 325 miles of road is unlikely to pose a significant long-term risk, relying entirely on project design features and BMPs rather than site-specific sediment modeling. The document does not quantify how much additional fine sediment the 325-mile haul network would deliver to these already-impaired, temperature-stressed streams during wet-season operations. The agency should commission a site-specific sediment budget analysis for Fall Creek and its listed tributaries before approving wet-season haul on aggregate-surfaced roads in this watershed.
- The mill capacity figure used to justify the project's economic contribution is based on 2008 data and the EA explicitly states 'there are no updated reports detailing current capacity.' The agency substitutes a working estimate of 1,000 MMBF without empirical support, then uses that unsupported figure to claim the 190 MMBF project represents about 19 percent of local mill capacity, a number that drives the entire economic justification. An outdated baseline from a pre-recession period inflates the apparent local need for federal timber. The agency should obtain current mill capacity data for Douglas and Lane Counties and recalculate the project's economic contribution on that basis before deciding.
- The EA's fire behavior analysis models pre- and post-thinning flame lengths under extreme wildfire conditions, but Table 5 shows that before thinning, 99 percent of stand acres already have flame lengths under 8 feet, and the post-thinning distribution is nearly identical. The document itself states 'commercial thinning would have minimal effect on fire behavior in the stands within the project area.' Yet fire risk reduction is cited in the Purpose and Need and used to justify why the alternative dropping fire-affected units was eliminated. The EA cannot simultaneously use fire risk reduction as a purpose-and-need rationale and acknowledge that modeled fire behavior is nearly unchanged by treatment. The agency should reconcile this internal contradiction and either remove fire risk reduction as a project justification or provide modeling that demonstrates a meaningful change in fire…
Show every point from the document
- The carbon analysis uses a forest-wide ForCaMF model calibrated to 1990-2011 harvest intensities, which the EA itself acknowledges 'is skewed towards picking up primarily more intensive harvest activity,' making the per-acre removal estimate more representative of clearcutting than thinning. The EA then applies this overestimate to 11,906 acres and calls the result an 'upper-bounds estimate,' but provides no lower-bounds or best estimate for the actual thinning intensity proposed. Presenting only an acknowledged overestimate without a central estimate prevents the public and decision-maker from understanding the probable carbon impact. The agency should provide a project-scale carbon estimate using thinning-specific data or a lower-bounds model before issuing a finding of no significant impact.
- The EA states that 63 known spotted owl home ranges overlap the project area and that most NSO territories are currently impaired due to habitat loss from the Jones, Gales, and Bedrock fires and past clearcutting. It then proposes to downgrade 301 acres of foraging habitat and further impair five core areas and nine home ranges. The document acknowledges that most site data comes from surveys conducted in the 1990s, meaning the current occupancy and territory boundaries for the majority of the 46 activity centers are unknown. Relying on decades-old survey data to conclude no incidental take will occur if surveys prior to implementation confirm territories are unoccupied is a deferred compliance mechanism, not a current effects determination. The agency should complete updated protocol surveys across all 63 home ranges overlapping the project area before authorizing any sale, not as a…
- The EA states that the new Temperature TMDL for the Willamette Basin was completed by ODEQ in June 2025, and that the Willamette National Forest will not complete its TMDL implementation plan until November 2026, after this EA is dated September 2026. The project proposes commercial thinning and log haul adjacent to three streams already listed as temperature-impaired, yet compliance with the new TMDL is deferred to a future plan that does not yet exist. The agency cannot demonstrate Clean Water Act consistency with a TMDL whose implementation plan has not been written. The agency should complete and make available for public review the new TMDL implementation plan before approving any project activities adjacent to Fall Creek, Hehe Creek, or Portland Creek.
- Tribal consultation letters were sent to the Confederated Tribes of Grand Ronde, Warm Springs, and Siletz on September 21, 2026, the same month the EA is dated, and the document states 'No comments have been received at this time.' Government-to-government consultation requires meaningful engagement, not a simultaneous letter-and-decision sequence. Sending consultation letters and finalizing the EA in the same month does not provide tribes adequate time to review 110 pages of analysis plus over 40 pages of project design features, consult internally, and respond substantively on cultural resources, sacred sites, or treaty interests. The agency should extend the comment period and hold the decision in abeyance until tribes have had a meaningful opportunity to respond.
- The stand exam data underlying harvest unit selection and volume estimates was collected from 2011 to 2022, with 2024 LiDAR used only to update canopy cover for post-fire effects. The EA acknowledges that three major fires burned between 2017 and 2023, and that initial stand selection came from the 2017 Lowell Country EA, which 'was updated after the 2017 Jones Fire but not after the 2021 and 2023 fires.' Ground-level stand exams are therefore as much as 15 years old for some units, predating two of the three fires. Using pre-fire ground data corrected only by remote-sensing canopy cover is insufficient to characterize current stocking, species composition, and snag density in units partially affected by fire. The agency should conduct updated field exams in all units that experienced any fire effects before finalizing volume estimates and harvest prescriptions.
- The EA proposes to thin 8,649 acres inside Late-Successional Reserves, which carry the highest conservation priority under the Northwest Forest Plan, yet it relies on a consistency review that it acknowledges 'tiered off the 2019 Lowell Country Environmental Assessment LSR consistency review.' The 2019 review preceded the 2021 Gales Fire, which burned approximately 28,103 acres of the Lowell Country project, and the 2023 Bedrock Fire, which burned approximately 29,560 acres of the same project. A consistency review anchored to pre-fire conditions cannot adequately evaluate whether post-fire LSR stands still qualify for thinning under Northwest Forest Plan Standards and Guidelines. The agency should obtain a new, independent LSR consistency review based on current post-fire conditions before authorizing any treatment in Late-Successional Reserve stands.
- 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
Project to address the need for vegetation management to increase stand growth and diversity and support the local economy. Proposed action includes commercial thinning harvest and restoration activities.
On the record for this fight
2 people have filed on this fight through PLAN. The official record is still catching up.
- Al, California36 seals
- and 1 more steward
Ranked on letters found on the agency’s record, then letters filed. Readers appear as first name and last initial, or as a steward in their state; switch yours off in your record. All boards
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 EA dismisses a no-temporary-road alternative by citing cost and feasibility, but the fire behavior analysis itself admits that immediately after harvest, before fuels treatments are complete, surf
The EA dismisses a no-temporary-road alternative by citing cost and feasibility, but the fire behavior analysis itself admits that immediately after harvest, before fuels treatments are complete, surface fuel loading increases and fire risk rises. The EA provides no estimate of how long the 21 miles of new temporary roads would remain on the landscape before rehabilitation is complete, nor does it analyze the sediment risk during that window. Section 'Alternative that Included No Temporary Road Construction' eliminates the alternative primarily on economic grounds without quantifying the sediment and fire-risk tradeoff during the post-harvest, pre-treatment interval. The agency should prepare a quantitative risk analysis comparing temporary road sediment delivery against the no-road scenario before finalizing any decision.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe EA acknowledges that Fall Creek, Hehe Creek, and Portland Creek are already listed as impaired under Clean Water Act Section 303(d) for year-round temperature, and that pre-spawn mortality of Spri
The EA acknowledges that Fall Creek, Hehe Creek, and Portland Creek are already listed as impaired under Clean Water Act Section 303(d) for year-round temperature, and that pre-spawn mortality of Spring Chinook salmon averages about 65 percent annually. Despite this, the sediment analysis concludes that log haul on 325 miles of road is unlikely to pose a significant long-term risk, relying entirely on project design features and BMPs rather than site-specific sediment modeling. The document does not quantify how much additional fine sediment the 325-mile haul network would deliver to these already-impaired, temperature-stressed streams during wet-season operations. The agency should commission a site-specific sediment budget analysis for Fall Creek and its listed tributaries before approving wet-season haul on aggregate-surfaced roads in this watershed.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe mill capacity figure used to justify the project's economic contribution is based on 2008 data and the EA explicitly states 'there are no updated reports detailing current capacity.' The agency su
The mill capacity figure used to justify the project's economic contribution is based on 2008 data and the EA explicitly states 'there are no updated reports detailing current capacity.' The agency substitutes a working estimate of 1,000 MMBF without empirical support, then uses that unsupported figure to claim the 190 MMBF project represents about 19 percent of local mill capacity, a number that drives the entire economic justification. An outdated baseline from a pre-recession period inflates the apparent local need for federal timber. The agency should obtain current mill capacity data for Douglas and Lane Counties and recalculate the project's economic contribution on that basis before deciding.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe EA's fire behavior analysis models pre- and post-thinning flame lengths under extreme wildfire conditions, but Table 5 shows that before thinning, 99 percent of stand acres already have flame leng
The EA's fire behavior analysis models pre- and post-thinning flame lengths under extreme wildfire conditions, but Table 5 shows that before thinning, 99 percent of stand acres already have flame lengths under 8 feet, and the post-thinning distribution is nearly identical. The document itself states 'commercial thinning would have minimal effect on fire behavior in the stands within the project area.' Yet fire risk reduction is cited in the Purpose and Need and used to justify why the alternative dropping fire-affected units was eliminated. The EA cannot simultaneously use fire risk reduction as a purpose-and-need rationale and acknowledge that modeled fire behavior is nearly unchanged by treatment. The agency should reconcile this internal contradiction and either remove fire risk reduction as a project justification or provide modeling that demonstrates a meaningful change in fire behavior attributable to the proposed action.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe carbon analysis uses a forest-wide ForCaMF model calibrated to 1990-2011 harvest intensities, which the EA itself acknowledges 'is skewed towards picking up primarily more intensive harvest activi
The carbon analysis uses a forest-wide ForCaMF model calibrated to 1990-2011 harvest intensities, which the EA itself acknowledges 'is skewed towards picking up primarily more intensive harvest activity,' making the per-acre removal estimate more representative of clearcutting than thinning. The EA then applies this overestimate to 11,906 acres and calls the result an 'upper-bounds estimate,' but provides no lower-bounds or best estimate for the actual thinning intensity proposed. Presenting only an acknowledged overestimate without a central estimate prevents the public and decision-maker from understanding the probable carbon impact. The agency should provide a project-scale carbon estimate using thinning-specific data or a lower-bounds model before issuing a finding of no significant impact.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe EA states that 63 known spotted owl home ranges overlap the project area and that most NSO territories are currently impaired due to habitat loss from the Jones, Gales, and Bedrock fires and past
The EA states that 63 known spotted owl home ranges overlap the project area and that most NSO territories are currently impaired due to habitat loss from the Jones, Gales, and Bedrock fires and past clearcutting. It then proposes to downgrade 301 acres of foraging habitat and further impair five core areas and nine home ranges. The document acknowledges that most site data comes from surveys conducted in the 1990s, meaning the current occupancy and territory boundaries for the majority of the 46 activity centers are unknown. Relying on decades-old survey data to conclude no incidental take will occur if surveys prior to implementation confirm territories are unoccupied is a deferred compliance mechanism, not a current effects determination. The agency should complete updated protocol surveys across all 63 home ranges overlapping the project area before authorizing any sale, not as a condition of individual sale contracts.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe EA states that the new Temperature TMDL for the Willamette Basin was completed by ODEQ in June 2025, and that the Willamette National Forest will not complete its TMDL implementation plan until No
The EA states that the new Temperature TMDL for the Willamette Basin was completed by ODEQ in June 2025, and that the Willamette National Forest will not complete its TMDL implementation plan until November 2026, after this EA is dated September 2026. The project proposes commercial thinning and log haul adjacent to three streams already listed as temperature-impaired, yet compliance with the new TMDL is deferred to a future plan that does not yet exist. The agency cannot demonstrate Clean Water Act consistency with a TMDL whose implementation plan has not been written. The agency should complete and make available for public review the new TMDL implementation plan before approving any project activities adjacent to Fall Creek, Hehe Creek, or Portland Creek.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingTribal consultation letters were sent to the Confederated Tribes of Grand Ronde, Warm Springs, and Siletz on September 21, 2026, the same month the EA is dated, and the document states 'No comments ha
Tribal consultation letters were sent to the Confederated Tribes of Grand Ronde, Warm Springs, and Siletz on September 21, 2026, the same month the EA is dated, and the document states 'No comments have been received at this time.' Government-to-government consultation requires meaningful engagement, not a simultaneous letter-and-decision sequence. Sending consultation letters and finalizing the EA in the same month does not provide tribes adequate time to review 110 pages of analysis plus over 40 pages of project design features, consult internally, and respond substantively on cultural resources, sacred sites, or treaty interests. The agency should extend the comment period and hold the decision in abeyance until tribes have had a meaningful opportunity to respond.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe stand exam data underlying harvest unit selection and volume estimates was collected from 2011 to 2022, with 2024 LiDAR used only to update canopy cover for post-fire effects.
The stand exam data underlying harvest unit selection and volume estimates was collected from 2011 to 2022, with 2024 LiDAR used only to update canopy cover for post-fire effects. The EA acknowledges that three major fires burned between 2017 and 2023, and that initial stand selection came from the 2017 Lowell Country EA, which 'was updated after the 2017 Jones Fire but not after the 2021 and 2023 fires.' Ground-level stand exams are therefore as much as 15 years old for some units, predating two of the three fires. Using pre-fire ground data corrected only by remote-sensing canopy cover is insufficient to characterize current stocking, species composition, and snag density in units partially affected by fire. The agency should conduct updated field exams in all units that experienced any fire effects before finalizing volume estimates and harvest prescriptions.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe EA proposes to thin 8,649 acres inside Late-Successional Reserves, which carry the highest conservation priority under the Northwest Forest Plan, yet it relies on a consistency review that it ackn
The EA proposes to thin 8,649 acres inside Late-Successional Reserves, which carry the highest conservation priority under the Northwest Forest Plan, yet it relies on a consistency review that it acknowledges 'tiered off the 2019 Lowell Country Environmental Assessment LSR consistency review.' The 2019 review preceded the 2021 Gales Fire, which burned approximately 28,103 acres of the Lowell Country project, and the 2023 Bedrock Fire, which burned approximately 29,560 acres of the same project. A consistency review anchored to pre-fire conditions cannot adequately evaluate whether post-fire LSR stands still qualify for thinning under Northwest Forest Plan Standards and Guidelines. The agency should obtain a new, independent LSR consistency review based on current post-fire conditions before authorizing any treatment in Late-Successional Reserve stands.
A hole PLAN found in the agency’s own analysis, quote verified against the document
The reporting behind this
From More Than Just ParksAfter more than a decade chasing peak color across America, we built the foliage map we always wanted.
More logging. Fewer protections for big trees, roadless country and wildlife. Another sweeping change to America’s public lands is moving fast.
Another foreign mining company wants a piece of America’s public lands. This one comes with millions of gallons of groundwater pumping and radioactive radon.
More actions that need you
Go deeper, free
See how your members of Congress vote on public lands
Every representative, graded on the votes that decide the fate of parks, forests, and refuges.
Open ↗The mapSee the places under active threat
A live map of the parks, monuments, and wild country in the crosshairs right now.
Open ↗A wrong fact, a dead link, a form that wouldn’t take your letter: one tap and it comes to the people who build PLAN, with this fight attached.
Know an open comment period we are missing, or spotted a wrong deadline? .