Mike Bader

The U.S. Forest Service created the Categorical Exclusion (CE) to exempt small projects like replacing picnic tables, an outhouse or rehabbing a campsite from National Environmental Policy Act analysis. However, the Forest Service is misapplying it to major federal actions across the West.

On the Bitterroot National Forest, the Eastside tree cutting project covers tens of thousands of acres. But the plan to expand the rustic Holland Lake Lodge on the Flathead National Forest into an upscale four-season resort is perhaps the most egregious example yet.

The Forest Service notice states: “Based on a preliminary assessment, intentions are to categorically exclude the proposed project from documentation in an environmental impact statement [EIS] or an environmental assessment.”

The permit covers 15 acres. The Lodge and buildings were found eligible for listing as a National Historic District. The permit holder claims development would honor the history and character and remain accessible to all. However, many buildings would be torn down and a 13,000 square foot lodge, 3,000 square foot restaurant and a total of 32 new buildings adding up to 33,000 square feet would be built. About 200 large trees would be cut down. It would be visible from every part of the lake.

The Flathead National Forest claims there would be substantial environmental analysis with a CE. Don’t buy it. The purpose of CEs is to exempt proposals from the detailed analysis done in an EIS. They would only evaluate 15 acres but impacts would reach much further.

The new permittee has developed mountain resorts across the West. With their foot in the door they could seek further expansion onto public lands with the possibility of heli-skiing, mountain bike trails, an aerial tram or a ski area. Real estate development is likely. The business model is an upscale destination not available to everybody. We see what follows. National Forests are impacted like the Big Sky area where development and recreation are out of control and there is pollution of the beloved Gallatin River.

The Forest Service website on CEs states: “…the agency must consider whether there are extraordinary circumstances which would preclude the use of the categorical exclusion… if extraordinary circumstances apply, the agency must conduct an environmental assessment or environmental impact statement.”

There are numerous extraordinary circumstances including habitat for the grizzly bear, lynx and bull trout, protected by the Endangered Species Act. The wolverine is proposed for protection and the area is a nesting site for loons.

The size (the list of proposed construction and infrastructure is four pages long), potential for expansion of the permit area and structures (reasonably foreseeable connected actions), its location next to the Bob Marshall Wilderness within a linkage area for grizzly bear recovery and its potential to alter the character and lifestyle of the Swan Valley also preclude a CE.

They tried to sneak an elephant inside the tent but this proposal requires the Forest Service to prepare an EIS. Better yet, they should declare the expansion is not in the public interest. The permit could be revoked and the Lodge and other buildings nominated for designation as a National Historic District and operated as a Visitor Center, Museum and boat dock accessible to all people.

Thinking plans for an upscale four-season resort can be categorically excluded represents poor judgment. Unless checked, the agency will continue to sweep environmental injuries under the rug. The Forest Service needs a reminder these public lands do not belong to them. They belong to the American people.

Public comments are accepted through October 7. Send to: https://www.fs.usda.gov/project/?project=61746

Mike Bader, Missoula, is an independent consultant and researcher with emphasis on grizzly bears, a conservationist and former seasonal Yellowstone ranger and firefighter. He frequently writes about natural resource issues in the western U.S.