When is a loss, a win?  It’s hard to tell with the U.S. Forest Service (FS), National Forests and Grasslands in Texas (NFGT), but it appears via Houston Regional Group and Lone Star Chapter of the Sierra Club (Sierra Club) efforts this has occurred with the proposed Harmon Creek Wildlife Habitat Improvement Project (HCWHIP).

On September 29, 2025, the Sierra Club participated in an objection meeting via phone with the FS about the proposed HCWHIP in Compartments 59, 60, 61, 62, and 63 of Sam Houston National Forest (SHNF).

This objection meeting was set up differently than other objection meetings that the Sierra Club has participated in for other NFGT proposed projects.  There were two people from the NFGT, two people from SHNF, and six people from the FS Region 6 or other national forests.

The objection process was different than the one the Sierra Club participated in, in the past.  There wasn’t any effort to have a conversation between the District Ranger and the Sierra Club about each objection issue.  Instead, Region 6 asked the Sierra Club whether it had any clarification to offer for objections.  The Sierra Club talked about the following objections:

1. Objection 1, the U.S. Forest Service Didn’t Engage in Collaboration With the Sierra Club as Defined by the U.S. Forest Service.

2. Objection 2, the FS Hasn’t Fulfilled the December 11, 2023 Sierra Club Freedom of Information Act (FOIA) Request for All Information Requested. 

3. Objection 3, the Level of Thinning for Many Stands is High and Approaches a Shelterwood Harvest Cut in Some Stands and RCW Requirements Aren’t Being Followed in the Proposed HCWHIP.

4. Objection 4, the FS Inaccurately States and Provides for Soil Protection in Riparian Areas.

5. Objection 5, the FS Will Cause Unnecessary Water Quality Degradation by Crossing a Perennial Stream and 13 Intermittent Streams.

6. Objective 6, the FS Hasn’t Reported the Old Growth Analysis Results for MA-4 Areas in the FEA.

7. Objective 7, the FS Hasn’t Provided the Public in the FEA/FONSI/DN What Site-Specific Shortleaf Pine Ecosystem Restoration is, What it Includes Other Than Planting and Tending Shortleaf Pines, and Provides No Information About How and What Grasses, Herbaceous Plants, Shrubs, and Understory, Midstory, and Overstory Trees Will be Used as Indicator Plants to Document Restoration of All of the Shortleaf Pine Ecosystem.

8. Objection 8, the FS Provides No Documents in the Recreation and Scenic Resources Section and Literature Cited Section for Any Analyses or Statements Made on Pages 30-32 of the FEA/FONSI/DN. 

9. Objection 9, the FS Provides No Documents in the Public Health and Safety Section and the Literature Cited Section for Most Analyses/Statements Made on Pages 32-33 in the Proposed HCWHIP FEA/FONSI/DN and Fails to Cover Important Potential Impacts Using Best Available Science. 

10. Objection 10, the FS Doesn’t Consider and Use Best Available Science for Site-Specific Environmental Analysis for Climate Change in the Proposed HCWHIP.

11. Objection 11, the FS Doesn’t Consider and Use Best Available Science for Site-Specific Environmental Analysis for Socioeconomic Issues/Concerns.

12. Objective 12, the FS Doesn’t Commit to No Mulching of the Wooded Knoll in Stand 10, Compartment 60, Proposed HCWHIP.

13. Objection 13, the FS Doesn’t List the Purpose and Need for the Proposed HCWHIP or that Recruitment of RCW is the Purpose of the Proposed HCWHIP.

The Sierra Club wasn’t hopeful of major changes from the FS for the proposed HCWHIP, because in the past Sierra Club concerns hadn’t been addressed.  When the proposed FS letter came on October 6, 2025, in nearly every case the Sierra Club objections were rejected.  However, the NFGT provided instructions to the SHNF District Ranger which addressed some of the Sierra Club objections.  The NFGT stated:

“Throughout the objection resolution meeting, I heard objectors' desires for increased public communication throughout the process, regardless of the level of NEPA, and acknowledging and documenting responses to concerns brought forward during any opportunity.”

“… I am instructing the Responsible Official, District Ranger of the Sam Houston National Forest, to take the following corrective actions:”

“Issue 11 Socioeconomic:  Include current socioeconomic data associated with forest tourism and recreation on the Sam Houston National Forest to the No Action Alternative for a more robust analysis, if this information is readily available. Capture federal forest percentage of commercial timberland if an updated number outside of the 1996 LMP exists.”

“Issue 3 Thinning Levels & RCW Guidelines:  The EA and Decision Notice should identify the deviation from MA-2-80-4.7 and include rationale for why this is appropriate.

“Issue 6 Old Growth:  The forest shall disclose the likely effects of prescribed fire on vegetation structure and composition in MA-4 stands, including likely effects of fire on old growth if they are present in the EA vegetation section.

“Issue 4 Soils:  Include the following LMP standards to provide additional protective measures for soils:  FW-023, FW-063-4, FW-063-5, FW-063-6, FW-204-15, FW-204-16, FW-204-17, FW-2041 8, FW-204-19, FW-211, MA-2-18, MA-2-71, MA-2-73, MA-2-74, MA-2-75, MA-2-76, MA-3-04, MA-3-34, MA-3-35, MA-3-101, MA-4-101, MA-4-103, MA-4-104, MA-4-109, MA-4-121.

“Based on the FS response on 9/16/24, the MA-4 needs to encompass all the Kanebreak soil mapping units or use the RLRMP guidance in MA-4 (p. 152) to delineate a secondary zone in the field.”

“1. The SHNF will expand MA-4 to encompass all mapped Kanebreak soils. This expansion of MA-4 will align the project with the Forest's response to comments from the DEA. A hydrological map of the Kanebreak soils will be included in the FEA.”

“Issue 5 Hydrology:  Include the other LMP standards and state BMPs that apply to stream crossings that are not in the EA (LRMP: FW-214 through 216, M-A-102 through 103; state BMPS: BMP 3.14 through 15, BMP 3.41 through 47, BMP 5.33).

“Correct on page 24 of the EA, "... 14 intermittent streams are crossed by logging equipment at the discretion and guidance of authorized personnel (Table 6)." This statement is incorrect. The statement shall read the following: "However, 13 intermittent streams are crossed by logging equipment at the discretion and guidance of authorized personnel (Table 6)."

These corrections will hopefully lead to a better and greener FS project and address some of the Sierra Club concerns.  This is what the Sierra Club wanted.  While we’ll wait and see how this project is implemented, sometimes a loss like this is actually a win.