League of Wilderness Defenders/Blue Mountains Biodiversity Project v. Connaughton

The federal district court for the District of Oregon vacated an environmental impact statement (EIS) and record of decision (ROD) for the Snow Basin Vegetation Management Project in the Wallowa Whitman National Forest in Oregon. In December 2014, the court ruled that the U.S. Forest Service defendants had not complied with the National Environmental Policy Act and the National Forest Management Act (although the court found no fault with the analysis of potential climate change impacts due to short-term reductions in the forest’s capacity to store carbon). In its order vacating the EIS and ROD, the court said that it would not void three timber sales contracts that the Forest Service had voluntarily suspended; the court concluded that the determination of what to do regarding the contracts was best left to the agency’s discretion.

The federal district court for the District of Oregon issued a mixed ruling on the merits of a challenge to a vegetation management plan that included some commercial logging. Although the court ruled for the plaintiffs on several claims under the National Environmental Policy Act (NEPA), the court ruled for the federal defendants on the climate change-related NEPA claim. In particular, the court rejected the plaintiffs’ argument that the United States Forest Service had failed to disclose the short-term negative impact that the project would have on the forest’s capacity to store carbon. The court found that the agency’s qualitative analysis of the project’s long-term benefits with respect to climate change was sufficient. The analysis had noted there was uncertainty regarding carbon sequestration’s relationship to climate change and that the project was consistent with the Intergovernmental Panel on Climate Change’s recommendations for forest management.

A federal district court denied plaintiffs’ motion for a preliminary injunction to stop the commencement of logging that was part of the Snow Basin Vegetation Management Project in the Wallowa Whitman National Forest in Oregon. Among other claims, plaintiffs contended that the environmental impact statement (EIS) for the project failed to discuss the impacts of logging on carbon storage. The court concluded that the United States Forest Service’s qualitative analysis had adequately addressed the project’s impacts on carbon sequestration and climate change, and that the agency had sufficiently supported “its determination that the Project would positively affect carbon sequestration and that carbon sequestration was insignificant because the Project would retain and thin trees rather than clear-cut tre[e]s."