Alliance for the Wild Rockies v. United States Forest Service

The National Forest Management Act (NFMA) required the United States Forest Service (service) (defendant) to develop a Land and Resource Management Plan (forest plan) for each national forest. The forest plan included standards, guidelines, and desired vegetative conditions for each forest. The service was required to comply with the standards but could depart from the guidelines if the reason for the departure was documented. The Payette National Forest (Payette) in Idaho was managed according to the 2003 Payette Forest Plan (2003 plan). The 2003 plan divided the Payette into different areas, each of which was assigned a management prescription category (MPC). The area designated MPC 5.1 emphasized restoration for habitat diversity. The area designated MPC 5.2 emphasized commodity uses such as timber production. In 2014, the service finalized the Lost Creek-Boulder Creek Landscape Restoration Project (2014 project), which would alter management practices in the Payette. However, the 2003 plan still remained in effect. The 2014 project replaced MPC 5.2 with MPC 5.1, eliminating binding fire standards. An environmental group, the Alliance for the Wild Rockies (alliance) (plaintiff), sued the service, arguing that the 2014 project was inconsistent with the 2003 plan. The service argued that the new fire rules were similar to or consistent with those in the 2003 plan and that the MPC 5.2 rules were outside the scope of the 2014 project. The alliance also argued that the 2014 project changed the definition of “old forest”—areas marked by large trees that were beneficial to wildlife. The old-forest standard under the 2003 plan required the service to maintain at least 20 percent of vegetation in large trees. The 2003 plan acknowledged the presence of large trees in the Payette. The service argued that the 2014 project did not alter the 2003 definition of old forest; however, the 2014 project’s environmental-impact statement claimed that no stands of old forest had been identified in the affected areas.