Science Education Professor on one of the largest logging and road-building projects in Wyoming’s history.

The following guest blog post is written by Duane Keown, a Professor Emeritus of Science Education at the University of Wyoming. The main topic is the U.S. Forest Service’s Landscape Analysis Vegetation, or LaVA, project on the Medicine Bow National Forest in southern Wyoming; however, Keown also digs into NEPA and recreation issues. Conservation groups say the LaVA is one of the largest logging and road-building projects in Wyoming’s history. The project would allow timber cutting on up to 320,000 acres over the next 15 years, including as much as 95,000 acres of clearcutting, as well as 80,000 acres of logging in designated roadless areas. It would bulldoze 600 miles of new, temporary roads that can remain on the ground for eight years or more, harming streams and degrading the watershed. – mk

Fifty years ago, on June 22, 1969, the Cuyahoga River in Cleveland caught fire. The river was one of the most polluted in the U.S. Journalists filled glasses with pitch-black river water. The Santa Barbara, California oil spill occurred in January and February1969 in Southern California. It smeared beaches for 12 miles and had a significant impact on marine life in the channel, killing an estimated 3,500 sea birds, as well as marine animals such as dolphins, elephant seals, and sea lions. Nearly 100,000 gallons of crude oil from a well pipeline owned by Union Oil lined the Santa Barbara Bay. It was the environmental shot heard around the world, the largest oil spill ever in the U.S. at the time. Public citizens had little authority over large private and governmental projects dangerous to the environment. Industry or governmental agencies called the shots for large forest logging operations, locations for oil pipelines, oil wells, large environmental disruptions. Washington state senator Henry “Scoop” Jackson caused that to change. He led Congress to sign the National Environmental Policy Act (NEPA). The Senate voted unanimously to approve the bill on July 10, 1969. The House approved its version of the bill on September 23, 1969, by a vote of 372-15. President Richard Nixon signed the bill into law on January 1, 1970. It is Environmental Impact Statements (EISs) and associated laws that are the tools of NEPA enforcement.

In its 50 years of existence some industries and governmental agencies have begun to do their best to skirt the peoples’ NEPA. In carrying out the Landscape Vegetation Analysis Project (LaVA), the largest commercial logging operation ever in Wyoming, officials of the Medicine Bow National Forest (MBNF) have evaded the NEPA at each of its stages for public involvement.

In the first stage of all EISs, the agency is to introduce the project to the public with a Scoping Meeting and document. The public and interested groups, by the Code of Federal Regulations (CFR §1501.7 Scoping) are to be notified, including wildlife organizations and environmental conservation groups. None of these groups in Wyoming were notified, like the Wyoming Outdoor Council and the Wyoming Wildlife Federation. And by CFR 40, page 102, the main public media outlets, in this case the Boomerang, was to be notified in good time before the meeting. The public was not notified by the Boomerang of the August 8, 2017 Scoping Meeting. But in the next public stage of the NEPA process, the Draft Environmental Impact Statement document the following June, it stated on page 22 of that document that on August 1 of 2017 the Boomerang notified the public. The MBNF Superintendent and the Coordinator of the LaVA knew well this was a cover up for their scoping errors. There are 36,000 residents of Albany County and fewer than 15 attended the Scoping Meeting. The public was not notified of this largest operation ever planned on the Medicine Bow National Forest.

With LaVA, six hundred miles of road for logging are contemplated, 95,000 acres (148 square miles) of clear-cutting are planned and the commercial logging of the forest in the first six years — a 15-year project — is to increase 800 % annually above the present commercial logging. The harvest is not of the 10 year old dead trees, but live trees. Nearly one third of the forest (260,000 acres) is up for commercial harvesting. And 380,000 acres is eligible for so called “treatment”. What a misnomer. The project is not about forest health, as most forest ecologists will tell you, but a veiled logging project straight out of Washington D.C,

According to the CFR, public meetings are to be held concerning the Final Environmental Impact Statement. At these three meetings, true public involvement was not allowed. They were LaVA sales meetings. My wife and I attended nearly all the NEPA meetings. There was no public discussion and we were not allowed in the meetings to set up our small table of scientific and legal information that countered LaVA planned actions. (A major study by the Colorado State School of Forestry and the University of Idaho concludes that because of climate change, burned Rocky Mountain forests are not regenerating, naturally or by forest crew’s plantings.) At the third meeting at the Cheyenne Public Utilities (CPU) building, a public owned building, we were not allowed by the manager in charge of the building to even put our small table outside the front door or on the CPU property. CPU is a LaVA Cooperator with MBNF. The manager had no idea what NEPA was about, its purpose, or our First Amendment rights.

By far the greatest use of the Medicine Bow is recreation. It already has the greatest density of roads of any Wyoming National Forest and also the greatest density of recreationists of all Wyoming National Forests. There are an equal number of green license plates from Colorado as Wyoming plates since the forest adjoins Colorado’s five million residents on the Eastern Slope. The Snowy Range has become Wyoming’s equivalent of the Rocky Mountain National Park. The LaVA plan will degrade this spectacular recreation site and tourist draw that means so much to Albany and Carbon counties of Wyoming. And I must add, guests from all over America. And that is not even to speak of the economic value of this National Forest to the two counties.

On August 1, last week, my wife and I recorded by numbers of vehicles and their states’ licenses, people recreating at all sites along Highway 130, the Snowy Range Road. We started at the east entrance and recorded the numbers of vehicles and their states at all of the turnouts, campgrounds and trailheads. Going west we included the Silver Lake Campground on the western slope and stopped there. Here is our count. Thirty-five states were represented: Wyoming 202 cars, Colorado 209, Nebraska 22, Texas 8, Iowa 8, Kentucky 3, Kansas 4, Utah 3, North Carolina 2, Alabama 3, Montana 4, California 4, Pennsylvania 2, Illinois 4, Missouri 3, Michigan 1, Wisconsin 10, Washington 1, Louisiana 1, Vermont 1, Oklahoma 2, Minnesota 1, Oregon 1, Arkansas 1, Florida 1, New Jersey 1 New Mexico 2, Idaho 1, Ohio 1, Tennessee 1, Mississippi 1, Virginia 3, and South Dakota 1. There were 12 cars for which we were not able to get their license. The total of cars counted August 1, 2020 was 518. The numbers increase yearly. Most parking lots were full and overflowing.

At the Libby Lake parking lot, cars were lined for a half mile from the lot at the trailheads. The Snowy Range Road where we counted vehicles in the plan is designated recreation area but it the primary road to many of the LaVA logging areas and their 600 miles of roads, with the resulting truck traffic. At this time the public awaits the MBNF Supervisor, Russell Bacon, to make the Record of Decision about continuance of the LaVA.

The Supervisor gave me this answer last May when I asked him for expenses to date on LaVA : “Use the Freedom of Information Act process for the entirety of your request” he said. What transparency! But based on the agency’s own numbers, over a 15-year period, the project will cost $255 million, a quarter of a billion dollars. According to the Modified Final EIS of May 2020, the cost for the 600 miles of temporary roads — never temporary for off road vehicles — is estimated to be three million dollars. What a price for decimating our national treasure.

9 thoughts on “Science Education Professor on one of the largest logging and road-building projects in Wyoming’s history.”

  1. It is funny (but not ‘funny, ha ha’) that the high cost of analysis (assuming here, until you get your FOIA request fulfilled) for such projects is part of the justification for changing / ‘streamlining’ NEPA processes. A decent argument, perhaps, if you believe that these projects are in the best interests of the land, the public, etc. But, as evidenced by there are specific industries (oil and gas, grazing, timber) or, charitably, specific portions of ‘the public’, for which/whom expedited work is being done.

    • Just sayin’ the Secretary writing a memorandum and speeding up NEPA at the forest or district level are two different things, let alone actually making a difference on the ground.
      Also I don’t believe that the “high cost of analysis” is necessarily a reason to streamline NEPA. Kitchen sinkery by litigants begets kitchen sinkery by agency folks in an otherwise endless cycle.

      I may not eat beef from federal lands (although I might choose it if it were certified) but I do use wood and oil and gas products. I don’t know if any are from federal lands. So I think there are benefits to the public from natural resource production on federal lands.

  2. I’ve also spent time in the Snowies and the Sierra Madre. Last fall, in the Sierra Madre, I noticed what appeared to be 1) hunters, 2) firewood cutters 3) folks on horseback rounding up the last of their cattle, 4) ATVers, 5) recreational horseback riders and 6) log trucks associated with felling hazard trees. There was a sign for a road closure for tree felling which was only for certain time periods so recreationists (including hunters) could get around, and they stopped to let us through exactly when the sign said they would.

    So…Keown says it would “degrade” recreation, but all these recreationists and workers seemed like they were doing just fine with each other. Question would be with regard to Matthew’s epistemological question, how could we actually know what recreationists think?

    If local/regional recreationists are more tolerant and infrequent visitors from other states are not, whose voices are more legitimate?

  3. I think it’s legitimate to assume that almost all recreationists will react adversely to clearcutting 280,000 acres (1/3 of forest) in the next 15 years, and 600 miles of road. This is a throwback to the reckless “timber at all costs” era. The good news is that this can be trash-canned soon after Trump and Perdue are gone, as can many other ill-advised gifts to commercial interests (e.g. dumping Tongass Roadless protections).

    • Historical note, Jim. I was on a phone call with CEQ and EPA during the Obama administration clearing the way for a condition-based large bark beetle project on the Black Hills. Remember these areas are full of dead trees.

      I believe the idea at the time was that larger projects would decrease the total time to analyze projects and the analysis would be more thoughtful than EA sized projects. I thought two things at the time… (1) bigger projects make bigger targets so better to litigate, and (2) when your large project doesn’t have high level Administration support a phone call away, (like all the other forests who may try to do the same thing) you may find that it won’t be successful.

      Here’s what their site says (and I visit the area and see the projects fairly frequently).

      “The Mountain Pine Beetle infestation has had widespread and noticeable impact in our forests. As of 2016, of the forested areas on the Snowy and Sierra Madre Ranges, approximately 50% of the trees are dead.

      Why do we need to act? This project will utilize beetle-killed timber while it is still marketable. Additionally, dead trees increase fuel loading, which increases the potential risk of fire, and puts communities – and lives, at risk. It can also impact the watershed, recreation opportunities, and wildlife habitats.

      The Forest Service has been working alongside multiple federal, state and local cooperating agencies since March of 2017 to develop plans for this project. We’ve worked closely with those agencies to develop the project time frame and purpose, and to identify values at risk which are in need of protection.”

      Trump took office on January 20, 2017 . Based on my experience, when the project started, it was much more likely to be the result of lots of dead trees across two mountain ranges, and the success of a neighboring forest in implementing a landscape-scale condition based approach.

      Note Sustainable Northwest’s post on landscape scale analysis for NEPA efficiency from November 22, 2016. That was the NEPA gestalt of the time prior to Trump.

  4. We talked about the prior iteration of this project here:

    It was, and apparently still is, another try at a “condition-based” project: “Conservation groups say the Forest Service violated environmental disclosure laws by not identifying where within the nearly 1,000 square mile project area the agency plans to log or build roads. The groups say that data is necessary to evaluate the proposal’s full impacts.”

    The Forest Service shouldn’t be surprised if it fails bigly like something similar did in Alaska.

  5. I think it is important to recognize the difference between what Sharon refers to as a “landscape scale condition-based approach” and a “landscape scale analysis for NEPA efficiency.” Here is what the latter would look like, according to Sustainable Northwest in 2016:

    “Identify mapped treatment units and apply prescriptions that would provide flexibility to forest managers during implementation. These treatments would be guided by a set of mitigation measures, limits on treatments by watershed based on Forest Plan Standards and Guidelines, or other constraints;
    Defer some survey work to after the NEPA decision has been made. This approach would require forest managers to complete and document a field review process either prior to making a decision or prior to implementation.”

    LaVA opponents are saying that it doesn’t identify treatment units (and maybe its Black Hills model got away with that). Regarding the second requirement, other condition-based approaches rule out considering new information that might arise from subsequent survey work in a second NEPA process. That could lead to a violation of NEPA.

  6. FYI – The Forest Service approved the LaVA project last week, although the agency removed the up-to-80,000 acres of treatments in Inventoried Roadless Areas. Still 600 miles of road and almost 290,000 acres of treatments (up to 95,000 acres of clearcuts) over the next 15 years. See

    For a competing view of the project, here’s the Sierra Club’s and WildEarth Guardians’ response:


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