First the Shell Game. Now the Bait and Switch.
- keepitopenfafa
- Aug 2
- 5 min read
For years, we have described Forest Service planning as a shell game.
The agency places an issue under one shell, moves the shells around, and expects the public to lose track of where the issue went.
Travel management is a good example.
The Forest Service says travel management and access are not part of this forest plan revision. Then we look inside the plan and find Recreation Opportunity Spectrum designations, management areas, standards, guidelines, and other direction that can shape future decisions about motorized access.
Travel management did not disappear. Important parts of its future foundation were placed under a different shell.
Timber is another example.
The agency says Alternative 2 increases timber production. That is true when compared with the greatly reduced amount being produced today. But Alternative 2’s projected timber output is still approximately 27 percent below the combined original 1990 plan baseline.
The agency shows the public the increase it wants us to see and hopes we will not look under the other shell.
Grazing follows the same pattern.
The agency says grazing will be maintained. But the current grazing level identified in the DEIS is approximately 34 percent below the original 1990 plan output.
Maintaining today’s reduced grazing level is not the same as maintaining the grazing opportunity provided under the plans being revised.
That is the shell game: move the issue, change the baseline, change the name, and keep the public chasing the shells around the table.
But with the release of the Draft Environmental Impact Statement, the game appears to have changed.
The shell game is still being played. Now we also appear to be dealing with a bait-and-switch.
Here Is What Happened
The Forest Service released the DEIS on July 2 and started the 90-day public comment period.
The public was told to review the DEIS, examine the agency’s analysis, and submit informed comments about its conclusions and alternatives.
The DEIS itself repeatedly directed readers to supplemental information for additional details.
These were not all casual references buried in a footnote:
Printed page 16 directed readers to Appendix H and supplemental information for more information.
Printed page 33 directed readers to Forest Products and Forest Vegetation Supplemental Information for a detailed comparison of active-management objectives.
Printed pages 38 and 69 said lists of unique habitats associated with Species of Conservation Concern could be found in supplemental documents.
Printed page 63 directed readers to “DEIS Supplemental Information 2026” for detailed information about how the alternatives comply with applicable direction.
We followed those directions.
We looked for the materials. We searched the Forest Service websites, public folders, hyperlinks, and document collections. We could not find them.
FAFA then asked the Forest Service to provide the supporting information needed to understand and test the DEIS conclusions.
The initial responses indicated that supporting documents would continue to come online, that the planning team was working to make materials available, and that some project-record material might not be available until later in the process.
Then the answer changed.
On July 22, after the comment period had already started, the Forest Service posted an errata stating that the DEIS had mistakenly referred to supplemental information on five pages. The errata said supplemental-information documents were not published with the DEIS and that the substantive analysis needed for public comment was already contained in the DEIS.
That is where this went from a shell game to something that operates like a bait-and-switch.
The public was first directed to supplemental information for detailed comparisons, habitat lists, compliance information, and additional explanation.
When the public could not find those materials and began asking questions, we were told more information would be coming.
Then we were told the references were mistakes and that we already had enough information to comment.
Call It What You Want
Can we prove this was intentional? No.
It may have been a serious drafting mistake, a failure in document review, a breakdown between the agency and its contractors, or something else. We are not going to claim we can prove the agency’s intent without the complete record.
But intent does not erase the effect on the public.
The Forest Service started a limited 90-day comment period with a DEIS that directed people to supplemental information that was not available. Members of the public then spent part of that limited period searching for those materials and asking the agency to provide them.
Crossing out the references after the comment period began does not give that time back.
It also does not answer the most basic questions.
If the referenced supplemental documents exist, why were they not published?
If they do not exist, where are the detailed comparisons, habitat lists, compliance information, assumptions, and supporting analysis that the DEIS said they contained?
If all the necessary analysis is already in the DEIS, why did the DEIS repeatedly direct the public somewhere else for more detailed information?
Calling those references mistakes does not create the missing detail. It only confirms that the public was originally told to look for information that was not provided.
From the public’s side of the table, that is a bait-and-switch.
The Fix Is Straightforward
The Forest Service should:
Identify whether each referenced supplemental document exists.
Immediately publish every referenced or relied-upon document that exists.
Provide a complete support-record index with direct links and plain descriptions of what each document contains.
Explain in writing which requested records do not exist, were not relied upon, or will not be provided.
Provide replacement analysis wherever the DEIS relied on information the agency now says was referenced by mistake.
Issue a clean, corrected DEIS showing every change instead of expecting the public to piece the changes together.
Withdraw and reissue the DEIS with the complete supporting record and restart the comment period.
At the absolute minimum, the Forest Service should substantially extend the comment period and ensure the public receives meaningful review time after the complete record is available.
The public should not lose comment time because the agency released an incomplete or incorrectly referenced document.
This Is One of 13 Issue Areas
Missing and later-disclaimed supporting information is only one of the 13 major issue areas covered by FAFA’s commenting tool.
The tool can also help you comment on motorized access, Recreation Opportunity Spectrum designations, timber, grazing, mining, household and community impacts, wildlife, Wild and Scenic Rivers, roadless and wilderness designations, the 1990 plan baseline, monitoring, and other problems identified during our review.
You do not need to understand every issue or write a legal brief.
You need to explain what information you tried to find, why you needed it, what you could not evaluate without it, and what the Forest Service must do to correct the problem.
You can say something as simple as:
The DEIS directed the public to supplemental information that was not available. The later errata does not resolve my concern because it does not provide the detailed information originally referenced or explain where that analysis can now be found. I cannot fully evaluate the alternatives and their effects without the supporting information. The Forest Service should provide a complete support-record index, publish the referenced and relied-upon materials, correct or replace any unsupported analysis, and provide additional time for public review.
The comment period ends September 30, 2026.
Do not let the agency move the issue under another shell. Do not let it change what the public was promised after the clock started and then tell us we already have enough.
Use FAFA’s commenting tool. Pick the issues that matter to you. Tell your story in your own words, identify what is wrong, and demand a clear fix.
Build your comment here:
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