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.

  • 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.

  • Securing favorable conditions of water flows is not a priority objective.

  • 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.

  • The plan is neither coherent nor complete in addressing issues that by law require full consideration.

Fail to comply with the National Environmental Policy Act.

  • 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.

  • Contain analyses and conclusions not properly founded.

  • The range of alternatives fails to produce distinguishable results during the lifetime of the plan for the issues on which the Decision was made.

  • 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.

  • The FEIS and ROD erect arbitrary barriers that block implementation of the HFQLG Pilot Project at the scale and pace specified in the Act.

Fail to comply with the Administrative Procedures Act.

  • Action to implement the HFQLG Pilot Project is unlawfully withheld or unreasonably delayed.

  • Restrictions are imposed and actions proposed that are arbitrary and capricious.

  • 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:

  • Implement CASPO Interim Guidelines until a new Decision is reached.

  • 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.

  • Issue a Supplemental EIS to correct legal deficiencies and other faults in the FEIS.

  • Assure full implementation of the HFQLG Pilot Project.

  • Support stewardship projects to learn more about land management and the relationship between the community and the land.

  • Issue a new Decision.