Case 6:21-cv-01228-MC Document 1 Filed 08/18/21 Page 1 of 14
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`
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`B. Parker Jones (OSB #191163)
`Law Offices of Charles M. Tebbutt, P.C.
`941 Lawrence St.
`Eugene, OR 97401
`541-344-3505
`parker@tebbuttlaw.com
`
`Timothy M. Bechtold (PHV pending)
`BECHTOLD LAW FIRM, PLLC
`P.O. Box 7051
`Missoula, MT 59807-7051
`406-721-1435
`tim@bechtoldlaw.net
`
`Attorneys for Plaintiffs
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF OREGON
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`COMPLAINT
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`Plaintiff,
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`FOREST SERVICE EMPLOYEES FOR
`ENVIRONMENTAL ETHICS,
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`
` vs.
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`DAVID WARNACK, Willamette National
`Forest Supervisor, and U.S. FOREST
`SERVICE,
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` Defendants.
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`Plaintiff alleges as follows:
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`COMPLAINT
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`B. Parker Jones (OSB #191163)
`Law Offices of Charles M. Tebbutt, P.C.
`941 Lawrence St.
`Eugene, OR 97401
`541-344-3505
`parker@tebbuttlaw.com
`
`Timothy M. Bechtold (PHV pending)
`BECHTOLD LAW FIRM, PLLC
`P.O. Box 7051
`Missoula, MT 59807-7051
`406-721-1435
`tim@bechtoldlaw.net
`
`Attorneys for Plaintiffs
`
`
`
`
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF OREGON
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`COMPLAINT
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`
`
`Plaintiff,
`
`FOREST SERVICE EMPLOYEES FOR
`ENVIRONMENTAL ETHICS,
`
`
` vs.
`
`DAVID WARNACK, Willamette National
`Forest Supervisor, and U.S. FOREST
`SERVICE,
`
` Defendants.
`
`
`Plaintiff alleges as follows:
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`COMPLAINT
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`Case 6:21-cv-01228-MC Document 1 Filed 08/18/21 Page 2 of 14
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`NATURE OF THE CASE
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`1.
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`This is an action for declaratory judgment and injunctive relief challenging
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`Defendants’ failure to analyze in an environmental assessment (“EA”) or
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`environmental impact statement (“EIS”) their decision to log about 20,000
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`acres in western Oregon’s Willamette National Forest. See Willamette 2020
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`Fires Roadside Danger (sic) Tree Reduction Project Decision Memo, August
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`14, 2021, attached here as Exhibit 2 (“Tree Reduction Project”). Instead of
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`completing an environmental review required by the National
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`Environmental Policy Act (“NEPA”), the Forest Service deemed the logging
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`to be “road maintenance” and excluded it from review in an EA or EIS. See
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`36 CFR § 220.6(d)(4) (listing grading and resurfacing of roads, cleaning
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`culverts, “pruning” vegetation, and clearing roadside “brush” without
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`herbicides as activities excluded categorically from environmental review).
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`2.
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`This action also challenges Defendant Warnack’s decision to log in Riparian
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`Reserves where logging is banned by the Northwest Forest Plan unless 1)
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`fire has “degraded riparian conditions” and, 2) logging is “required” to meet
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`Aquatic Conservation Strategy Objectives. Defendants have failed to
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`COMPLAINT
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`Case 6:21-cv-01228-MC Document 1 Filed 08/18/21 Page 3 of 14
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`demonstrate that either condition has been met, in violation of the
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`National Forest Management Act (“NFMA”), 16 U.S.C. § 1604(i).
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`JURISDICTION AND VENUE
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`3.
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`This Court has jurisdiction pursuant to 28 U.S.C. § 1331 (federal question), §
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`2201 (declaratory judgment), § 2202 (further relief), and the Administrative
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`Procedures Act (“APA”), 5 U.S.C. § 701-06.
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`4.
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`Venue is appropriate in this judicial district and in this Court under 28 U.S.C.
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`§ 1391(e) because Defendants and Plaintiff reside in this judicial district and
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`a substantial part of the events or omissions giving rise to the claims herein
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`occurred in this district.
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`PARTIES
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`5.
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`Plaintiff FOREST SERVICE EMPLOYEES FOR ENVIRONMENTAL ETHICS is a
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`national environmental organization founded in 1989, incorporated in
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`Oregon, with its headquarters in Eugene, Oregon. FSEEE has 8,000
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`members nationwide, including members in Oregon. FSEEE’s mission is to
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`protect national forests and to reform the U.S. Forest Service by advocating
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`environmental ethics, educating citizens, and defending whistleblowers.
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`FSEEE and its members have long-standing interest and expertise in
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`COMPLAINT
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`PAGE 3 OF 14
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`Case 6:21-cv-01228-MC Document 1 Filed 08/18/21 Page 4 of 14
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`national forest management. FSEEE’s members live, work, recreate, and
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`engage in other activities that have been, are being, and will continue to be
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`adversely impacted by the proposed logging. See Exhibit 1, Declaration of
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`Andy Stahl. In addition, the aesthetic, conservation, recreational, economic,
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`scientific, informational, and procedural interests of FSEEE and its members
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`have been, are being, and, unless the relief prayed for herein is granted,
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`will continue to be adversely affected and irreparably injured by the U.S.
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`Forest Service’s failure to comply with federal law as described below.
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`6.
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`Defendant DAVID WARNACK is Forest Supervisor of the Willamette
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`National Forest and made the decision to log challenged in this Complaint.
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`He is sued in his official capacity
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`7.
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`Defendant U.S. FOREST SERVICE, an agency of the U.S. Department of
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`Agriculture, manages the land on which the logging challenged in this
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`Complaint will occur.
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`FACTS RELEVANT TO PLAINTIFF’S CLAIMS
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`8.
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`During the summer and fall of 2020, three fires (Holiday Farm, Beachie
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`Creek, and Lionshead fires) burned vegetation affecting about 176,000
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`acres of the Willamette National Forest. The fires generally burned in a
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`Case 6:21-cv-01228-MC Document 1 Filed 08/18/21 Page 5 of 14
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`mosaic pattern with a majority of the national forest area burning at a low
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`to moderate severity. Such fires are relatively infrequent in western
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`Oregon’s Cascade mountains with a mean fire return interval of about 150
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`years. Some locations, such as ridgetops and dry south-facing slopes acres
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`burn more frequently than the average, while others, such as moist valley
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`bottoms and north-facing slopes burn less frequently.
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`9.
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`The three 2020 fires burned in a manner consistent with past scientific
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`studies of the area’s fire ecology. Fire influences and shapes the natural
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`growth and development of this area’s forests. For example, fires are the
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`predominant method by which dead trees, called “snags,” are created.
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`Fires play a major role in how nutrients are cycled from trees to soil. Fires
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`create habitat niches for many wildlife species, such as woodpeckers, that
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`are adapted to the environmental conditions that fires create. Fire is a
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`common disturbance in streamside, riparian areas, too. Fish species are
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`well-adapted to wildfires. Fires deposit logs, gravel, and nutrients in
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`streams that fish rely upon.
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`10.
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`Logging after a forest fire is not a natural ecological process. Logging
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`removes biomass that would otherwise remain in the forest. Logging
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`COMPLAINT
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`PAGE 5 OF 14
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`Case 6:21-cv-01228-MC Document 1 Filed 08/18/21 Page 6 of 14
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`removes dead and live trees that would otherwise remain in the forest. The
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`environmental effects of logging depend on the type of trees removed, how
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`many are removed, over how large an area, and the trees’ location on the
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`landscape, e.g., near streams. Comparing the environmental effects of
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`logging versus not logging, i.e., “no action,” is one of the purposes of an
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`environmental assessment. The Forest Service did not compare the
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`environmental effects of logging versus “no action” when it decided to log.
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`11.
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`Logging is not “road maintenance” and, thus, not excluded from
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`environmental review under NEPA. When the Forest Service promulgated
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`the “road maintenance” categorical exclusion rule, 36 CFR § 220.6(d)(4),
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`the Forest Service did not 1) notify the public that “road maintenance”
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`includes logging; 2) list logging within the rule’s scope; nor, 3) provide a
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`rational explanation, including the factual and scientific basis, for why
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`logging does not have significant effects and warrants exclusion from
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`environmental review. As applied to the logging decision challenged here,
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`relying on the “road maintenance” categorical exclusion rule exceeds the
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`Forest Service’s statutory authority under NEPA.
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`COMPLAINT
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`PAGE 6 OF 14
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`Case 6:21-cv-01228-MC Document 1 Filed 08/18/21 Page 7 of 14
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`12.
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`Logging thousands of acres, including tens of thousands of large, old trees,
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`may have significant adverse environmental effects on the human
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`environment, including on wildlife habitat and species, fish habitat and
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`species, carbon sequestration, noxious weed encroachment, and
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`recreational enjoyment of the affected forests. The Forest Service has not
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`assessed these effects in an EA or EIS.
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`13.
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`The environmental effects of logging will occur regardless of the need or
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`justification for the logging. Whether the logging is intended to provide
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`wood to lumber mills, revenue to the Forest Service’s budget, roadways
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`safer from the risk of falling trees, or a combination of the foregoing, does
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`not affect the impact logging will have on, inter alia, wildlife, fish, carbon
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`storage, weeds, visual quality, or recreation. However, not only have the
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`environmental impacts not been disclosed in an EA or EIS, the purported
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`benefits to mills, budgets, or public safety have also not been disclosed,
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`denying the public (and the decisionmaker) a meaningful opportunity to
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`weigh the alleged benefits of this logging versus its environmental costs.
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`COMPLAINT
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`PAGE 7 OF 14
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`Case 6:21-cv-01228-MC Document 1 Filed 08/18/21 Page 8 of 14
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`14. Notwithstanding the project’s title – “Willamette 2020 Fires Roadside
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`Danger Tree Reduction” – the Forest Service did not consider any safety or
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`risk data associated with trees falling when it decided to log.
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`15.
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`It is an inescapable fact of entropy that all trees fall down at some point
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`during their existence. Most trees that fall down are alive when they fall,
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`while the remaining trees are dead when they fall. Across all federal lands
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`in the United States, one percent (one person per year) of fatalities
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`suffered by the visiting public are caused by a tree falling down. Falling over
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`while hiking or climbing is the leading cause of backcountry deaths,
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`accounting for about 40% of fatalities. Avalanches (15%), drowning (10%),
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`heart attack (10%) and getting lost (6%) round out the top five. Being killed
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`by a tree is about as likely as being killed by a bear. The risk to forest
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`visitors associated with trees (whether living, dying or dead) falling on them
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`are trivial compared to other risks routinely accepted by people who visit,
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`recreate, or work on our national forests.
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`16. Most of the roads along which the logging will occur are managed by
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`Defendants as “maintenance level 2” roads suitable only for high-clearance,
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`not regular passenger, vehicles. Maintenance level 2 roads receive
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`COMPLAINT
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`PAGE 8 OF 14
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`Case 6:21-cv-01228-MC Document 1 Filed 08/18/21 Page 9 of 14
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`infrequent use by the public and Forest Service employees compared to
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`highways and other roads suitable for regular passenger vehicles. In
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`deciding to log, the Forest Service did not consider the differential safety
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`risks associated with different levels of road use.
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`17. Cutting down trees, whether dead or alive, is one of America’s most
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`dangerous professions. When fallers cut a tree, the chance that they are in
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`the potential kill zone is a 100% certainty. When natural forces cause a tree
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`to fall the odds that anyone is in the potential kill zone are de minimus. The
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`Forest Service did not consider these relative risks in deciding to log.
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`18. A preliminary injunction of the proposed logging is necessary to preserve
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`the status quo pending a determination of the action on the merits. A
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`preliminary injunction should issue because Plaintiffs have either a
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`combination of probable success on the merits and the possibility of
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`irreparable injury or serious questions are raised and the balance of
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`hardships tips in Plaintiffs’ favor.
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`19.
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`The Willamette National Forest Land and Resource Management Plan, as
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`amended, generally prohibits logging within Riparian Reserves. This project
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`proposes to log timber from Riparian Reserves. Notwithstanding this
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`COMPLAINT
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`PAGE 9 OF 14
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`Case 6:21-cv-01228-MC Document 1 Filed 08/18/21 Page 10 of 14
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`general prohibition against logging, if a fire results in “degraded riparian
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`conditions,” logging is permitted “if required to attain Aquatic Conservation
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`Strategy Objectives.” Exhibit 2 at 18.
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`20. Defendants have failed to determine that these fires degraded riparian
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`conditions and have failed to determine that logging is required to attain
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`Aquatic Conservation Strategy Objectives.
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`21.
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`The fires have not degraded riparian conditions and logging is not required
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`to attain Aquatic Conservation Strategy Objectives.
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`22. On April 12, 2021, FSEEE sent an email message to the Forest Service asking
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`“[u]nder which CE does the FS believe the 2020 Roadside Danger Tree
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`Reduction project qualifies?” See Declaration of Andy Stahl, Aug. 18, 2021,
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`¶11, Exhibit A, attached here as Exhibit 1. On April 13, 2021, the Forest
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`Service responded: “We expect the project to be completed under the
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`categorical exclusion for the repair and maintenance of roads (36 CFR
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`220.6(d)(4)).” Stahl Declaration Exhibit A. On the same date, FSEEE
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`submitted its comments on the proposed logging, noting the
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`inappropriateness of relying on the road maintenance CE rule to justify
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`logging. Stahl Declaration Exhibit B.
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`COMPLAINT
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`PAGE 10 OF 14
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`Case 6:21-cv-01228-MC Document 1 Filed 08/18/21 Page 11 of 14
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`CLAIMS FOR RELIEF
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`COUNT 1 – Defendants Violate NEPA
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`23. Plaintiff incorporates all paragraphs in this Complaint as though fully stated
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`here.
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`24. Defendants’ decision approving the Willamette 2020 Fires Roadside Danger
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`Tree Reduction Project is a final agency action subject to judicial review
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`under the APA, 5 U.S.C. §§ 702, 704.
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`25. NEPA requires federal agencies to prepare an EA to determine whether an
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`action may have significant effects on the environment and, if so, an EIS to
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`examine the direct and reasonably foreseeable indirect effects, and
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`alternatives to the federal action. 42 U.S.C. § 4332; 40 CFR § 1501.4; 40 CFR
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`§ 1508.8.
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`26.
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`Logging 20,000 acres is a major federal action that may have significant
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`environmental effects.
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`27.
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`Logging 20,000 acres is not routine road maintenance and, thus, is not
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`categorically excluded from NEPA review in an EA or EIS.
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`28.
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`The Forest Service did not 1) notify the public that “road maintenance”
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`includes logging; 2) list logging within the rule’s scope; nor, 3) provide a
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`COMPLAINT
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`PAGE 11 OF 14
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`Case 6:21-cv-01228-MC Document 1 Filed 08/18/21 Page 12 of 14
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`rational explanation, including the factual and scientific basis, for why
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`logging does not have significant effects and warrants exclusion from
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`environmental review. As applied to the logging decision challenged here,
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`relying on the “road maintenance” categorical exclusion rule exceeds the
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`Forest Service’s statutory authority, in violation of 42 U.S.C. § 4332, et seq.,
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`and the APA, 5 U.S.C. § 706.
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`COUNT 2 – Defendants Violate NFMA
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`29. Plaintiff incorporates all paragraphs in this Complaint as though fully stated
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`here.
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`30. Defendants will contract for the felling and sale of the timber to be logged
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`in this project.
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`31. NFMA requires that contracts be consistent with the land management
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`plan. 16 U.S.C. 1604(i).
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`32. Contracting for the sale of trees from Riparian Reserves violates the
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`Willamette national forest land and resource management plan, as
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`amended, because the fires did not degrade riparian conditions and logging
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`is not required to attain Aquatic Conservation Strategy Objectives, all in
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`violation of 16 U.S.C. 1604(i).
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`COMPLAINT
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`PAGE 12 OF 14
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`Case 6:21-cv-01228-MC Document 1 Filed 08/18/21 Page 13 of 14
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`PRAYER FOR RELIEF
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`Plaintiff respectfully requests that the Court:
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`A.
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`Adjudge and declare that Defendants violated NEPA and the APA when
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`they approved the Tree Reduction Project;
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`B.
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`Adjudge and declare that 36 CFR § 220.6(d)(4) is invalid as applied to the
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`Tree Reduction Project;
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`C.
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`Adjudge and declare that Defendants violated NFMA and the APA when
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`it approved the Tree Reduction Project;
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`D.
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`Enjoin Defendants from implementing the Tree Reduction Project,
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`either by contract or otherwise, until Defendants have fully complied
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`with NEPA and NFMA.
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`E.
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`Award Plaintiff its reasonable fees, expenses, costs, and disbursements,
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`including attorneys’ fees associated with this litigation, under the Equal
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`Access to Justice Act, 28 U.S.C. § 2412; and,
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`F.
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`Grant Plaintiff such further and additional relief as the Court may deem
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`just and proper.
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`COMPLAINT
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`PAGE 13 OF 14
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`Case 6:21-cv-01228-MC Document 1 Filed 08/18/21 Page 14 of 14
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`
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`DATED this 18th day of August, 2021.
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`____________________
`B. Parker Jones (OSB #191163)
`941 Lawrence Street
`Eugene, OR 97401
`(541) 344-3505
`parker@tebbuttlaw.com
`
`s/Timothy M. Bechtold
`Timothy M. Bechtold
`BECHTOLD LAW FIRM, PLLC
`P.O. Box 7051
`Missoula, MT 59807-7051
`406-721-1435
`tim@bechtoldlaw.net
`
`Attorneys for Plaintiff
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`CORPORATE DISCLOSURE STATEMENT
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`Pursuant to FRCP 7.1, Plaintiff discloses that it does not have parent
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`corporations, nor does the Plaintiff organization have stock.
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`COMPLAINT
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`PAGE 14 OF 14
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