Restoration for What? Northern Escarpment Project a Mismatch of Intentions, Actions, Science, and Process

Chris Gish
19 hours ago
7 min read

Updated: 18 minutes ago

Submit comments by February 11 on the Northern Escarpment Project, a prescribed burning, tree cutting, and herbicide application proposal on up to 2,770 acres of the Moosalamoo NRA near Middlebury — which the Forest Service is attempting to move forward without substantive environmental review.

Members of the Standing Trees community visited the Northern Escarpment Project area last summer, hiking up to Chandler Ridge, learning about the unique history of this place, and discussing the rationale for the “restoration” project the Forest Service has now put forward.

The Northern Escarpment Ecological Restoration and Fire Resilience Project is a proposal to combine tree cutting, herbicides, and repeated prescribed burns on 2,770 acres of the Western Green Mountain National Forest in Middlebury, Salisbury, and Leicester. The project targets one of the most beloved and scenic parts of the Green Mountain National Forest — stretches of the Moosalamoo National Recreation Area including Chandler Ridge and many of the hills and mountains north of Lake Dunmore.

We’re excited that the Green Mountain National Forest is interested in protecting and restoring rare natural communities, but we have a lot of unanswered questions about this large-scale, intensive project. Across Southern New England and the Mid-Atlantic, “restoration” of (supposedly) fire-adapted natural communities has become a major, often mis-used, justification for highly impactful logging, burning, and herbicide projects. This rationale is relatively new to Vermont, and we want to make sure the Green Mountain National Forest adopts the soundest reasoning and the most beneficial practices if they move forward with this project. We also want to push back on the use of “Categorical Exclusions" to rush the review process for this project. This is the same tactic that the Trump Administration and allies are pushing nationwide, via executive actions and bills like the “Fix our Forests” Act, to cut the public out of decision-making and fast track public lands extraction.

Join us in making sure the Northern Escarpment project is planning the best actions, for the right reasons, on an appropriate scale, and with the proper process. The comment period that closes on February 11 is likely to be the public’s only chance to weigh in on this project.

How to Comment:

Submit your comments on the Northern Escarpment Project by February 11 at this link. The Forest Service is intending to approve this project with a Categorical Exclusion, which means now is likely the only chance anyone has to comment on the project. The Forest Service has told us they plan to release more information on the project after the comment period closes; in other words, the public is still in the dark of the full rationale and evidence the forest service will offer for the project.

A couple dozen people braved a snowy evening to attend the Forest Service open house about the Northern Escarpment Project — an event, that, sadly, was not made more accessible by a recording or virtual option.

Below, we lay out our top concerns with the project. Know that you don’t by any means have to include all these same concerns. It’s most important that you share your personal connection to the project area and any issues that particularly resonate with you — hopefully the thoughts we include are a good place to start!

See complete project documentation at the Forest Service website here.

Submit your comments here by February 11.

Our Concerns

The public deserves a more robust and transparent process:

The Forest Service needs to conduct an environmental assessment and offer an additional comment period on this project, after the public has a reasonable chance to review all the relevant information and ground-truth the areas targeted for burning, cutting and herbicides. The first detailed information the public saw about this project was in January 2026, and the Forest Service wants to begin implementing the project in April 2026, after just one, 30-day comment period — not nearly enough time to let the public sort through and help refine this project, or to let the Forest Service honestly respond to the public’s concerns.

So far, the rushed, haphazard process for this project has included:

Relying on a “Categorical Exclusion” that shields the project from detailed environmental review — the same tactic the Trump administration has embraced across the country to approve large projects with minimal accountability.
Information shared at an unrecorded, in-person-only public meeting that was not available on the project webpage or in any other form.
Key project documents added to the project webpage halfway through the only comment period. Giving the public only two weeks to respond to an ever-changing project record is ridiculous. The current comment period needs to be followed by an environmental assessment and at least one additional comment period, where the public can respond to the full project record and whatever analysis the Forest Service does on the project.
A lack of evidence and the best available science. Federal agencies are legally required to put forward reasoned explanations, consider the best available science, and weigh all important aspects of an issue before deciding on a project. The Forest Service needs to provide more evidence for many parts of the project (see “Specific Issues,” below) and walk the public through their reasoning with specific citations, rather than making the public wade through an unexplained Literature folder in project documentation.

2. Specific Issues:

In addition to our concerns with the lack of an inclusive, and substantive review process, we have the following concerns about specific parts of the proposed action.

Hazardous fuels: The project’s first stated purpose is to “reduce hazardous fuels in the project area,” but are hazardous fuels actually a danger to human communities in the area, and, if so, is the proposal actually a reasonable way to address this risk? Besides the fact that only an average of 124 acres burn each year across the entire state, we don’t understand how removing mid-story vegetation (which will increase wind speeds, one of the primary factors increasing fire damage to human communities) and encouraging more xeric, fire-prone species will reduce fire risk. Furthermore, abundant evidence shows that home hardening, defensible spaces, and other measures taken in human communities, not wildlands vegetation treatments, are by far the most practical and effective ways to protect communities from fire. If fire protection is the goal, our public agencies should be putting resources toward community protection, not large-scale, uncertain vegetation treatments.
Historic Fire Regimes and Natural Communities: What is the long-term history of fire and fire-adapted natural communities in the project area? The evidence the Forest Service has put forward deals with the recent, settler-colonial past in the 19th and 20th centuries, which was a time of exceptionally high fire occurrence because of clear-cut logging and other human activities. According to Forest Service “Landfire” data layers, only a small portion of the project area can actually be classified as a fire-adapted ecosystem — Northern Hardwood forests, which have a fire return interval of 650-1000 years, make up an astonishing 73% of the area that would be open to burning. How is applying prescribed fire up to 5 times in 15 years reasonable “restoration” for these areas?

Project map shows the extent of the four treatment areas in the Northern Escarpment Project.

Regeneration of Oak, Pitch Pine, and other Desired Species: The Forest Service claims that burning and vegetation treatments are necessary to help oak, pitch pine, and desired shrubs regenerate, but evidence is far from clear on this. Vermont’s most detailed guide to natural communities cautions that “other processes besides fire can maintain” dry oak forests, and monitoring at the the only comparable prescribed fire project the Forest Service has pointed to in Vermont shows that prescribed fire “did not stimulate the regeneration of oaks or ericaceous shrubs” like blueberry and early azalea. Many of New England’s best examples of ridgetop pitch pine, meanwhile, do not have fire-adapted cones or show signs of fire as a major ecological process. The Forest Service needs to thoroughly consider deer browse, climatic, and other factors that likely affect species regeneration before diving into this impactful, large-scale project.
Endangered Species: The Forest Service needs to provide surveys and site-specific analysis of rare, threatened, and endangered species before closing public input on the project. We are particularly concerned about the federally-endangered Indiana bat, whose range is likely moving northeast and to higher elevations as the climate warms, and, even 20 years ago, was known in the GMNF Forest Plan (p. 27) to have potential roosting habitat in the Northern Escarpment project area.
Herbicide use: The project allows the use of triclopyr and glyphosate herbicides across up to 846 acres, with no specific limitations on how often or how much herbicide can be applied. A cornerstone study underpinning the safety of glyphosate (the active ingredient in RoundUp) was recently retracted, and both these chemicals bring risks for human health, soil health, ecological function, and potential PFAS contamination from "inert" ingredients. Our public lands managers should be modeling forward-thinking, ecological management — not finding new rationales to apply chemicals to native species in some of the wildest parts of our region.
Impacts to hydrology and carbon storage: The Forest Service needs to estimate carbon emissions from the project and evaluate changes to hydrology and future carbon accumulation. These are essential considerations for any ‘management’ project on Vermont’s public lands, and receive little consideration in current project documents.

3. The Forest Service needs to consider alternatives:

A large-scale burning, cutting, and herbicide project is not the only way to “restore” natural communities on the Green Mountain Escarpment. The Forest Service needs to consider less-impactful alternatives, including alternatives which:

Let natural fires burn: If fire-adapted natural communities belong in the project area, natural processes should be able to maintain them. The Forest Service should analyze ways to let natural, lightning-caused fires burn, and focus on protecting communities as needed through home hardening, community planning, and defensible space.
Reduce the scale of the prescribed fire: According to the Forest Service’s “Landfire” spatial data, only 15% of the project area could possibly be classified as a fire-adapted community. Much of the rest of the project area is Northern Hardwood forest, where there is no ecological justification for repeatedly burning up to 5 times in 15 years. The Forest Service needs to provide an alternative that targets prescribed fire and other interventions only on the existing areas of fire-adapted natural communities.
Eliminate the use of herbicides: Herbicides like Glyphosate and Triclopyr have many understudied, “profound” impacts. The Forest Service should pursue a project that accomplishes any needed restoration without resorting to the use of herbicides, especially on native plant species.
Maintain untreated controls: The long-term, natural fire history, and the impacts of applying fire on the landscape, are both far from clear for the Northern Escarpment Project. Given these uncertainties, the Forest Service should analyze an alternative that leaves some of the “ecological benefit” areas untreated by fire, cutting, and herbicides, to observe how they develop compared to the communities that are treated.

Want more information? We have more to share — please reach out for more details on these or any other issues related to the Northern Escarpment Project, and don't forget to submit your comment by February 11.