QLG Appeal of the
SNFPA Decision |
page 4 |
One Page
Summary
Basis of the QLG Appeal.
The FEIS and ROD are fatally deficient in law, regulation, technical
competence professional integrity, and do not implement Forest
Service policy.
The FEIS and ROD do not assure full implementation of the HFQLG Act
and the Pilot Project it specifies. In fact, this Decision works
unlawfully against such implementation.
Legal Deficiencies.
The Final Environmental Impact Statement and Record of
Decision.
Fail to comply with the Organic Act and the Multiple Use Sustained
Yield Act.
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Timber production is not a recognized objective, is not provided
for, and would virtually be prohibited by the standards and
guidelines specified in the FEIS and ROD.
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Securing favorable conditions of water flows is not a priority
objective.
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Neither adequate analysis nor appropriate weight are given to
adverse economic and social effects on Sierra Nevada populations
from implementation of the Decision.
Fail to comply with the National Forest Management Act.
Fail to comply with the National Environmental Policy Act.
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Do not deal with issues of significance to the proposed actions,
either ignoring them or putting them off with indefinite promises or
to non-NEPA processes.
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Contain analyses and conclusions not properly founded.
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The range of alternatives fails to produce distinguishable
results during the lifetime of the plan for the issues on which the
Decision was made.
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The chosen alternative was not disclosed to the public prior to the
Decision.
Fail to be consistent with the Herger-Feinstein Quincy Library Group
Forest Recovery Act.
Fail to comply with the Administrative Procedures Act.
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Action to implement the HFQLG Pilot Project is unlawfully
withheld or unreasonably delayed.
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Restrictions are imposed and actions proposed that are arbitrary and
capricious.
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Goals are stated, claims made, and conclusions drawn that are not
supported by data and analyses provided.
Fail to reflect adequate consultation with local indigenous people.
Relief Requested.
Withdraw the ROD and remand with instructions that include:
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Implement CASPO Interim Guidelines until a new Decision is reached.
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Initiate fuel reduction in Urban Wildland Intermix Zones at the
scale and pace of the Cohesive Strategy, and in DFPZs around
communities and across the landscape in the QLG area at the scale
and pace stated in the HFQLG Act.
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Issue a Supplemental EIS to correct legal deficiencies and other
faults in the FEIS.
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Assure full implementation of the HFQLG Pilot Project.
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Support stewardship projects to learn more about land management
and the relationship between the community and the land.
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Issue a new Decision.
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