## Facts

- The Payette National Forest is managed under the 2003 Payette National Forest Land and Resource Management Plan adopted pursuant to the National Forest Management Act (NFMA).
- The plan divides the forest into Management Prescription Categories (MPCs), including MPC 5.1 (restoration and habitat diversity) and MPC 5.2 (commodity production, including timber).
- In 2014, the Forest Service approved the Lost Creek–Boulder Creek Landscape Restoration Project, covering roughly 80,000 acres and authorizing vegetation treatments and prescribed fire intended to improve forest health and reduce fire risk.
- The Project converted portions of the project area from MPC 5.2 to MPC 5.1, which Alliance claimed effectively removed mandatory fire-management direction applicable in MPC 5.2 areas.
- The plan includes a mandatory “old forest” standard requiring that at least 20% of certain vegetation types be maintained in a large-tree, old-forest condition.
- The Project’s analysis stated that no old-forest stands had been identified in the project area; Alliance argued this effectively changed the baseline or operative application of the plan’s old-forest standard.
- Environmental organizations sued, alleging NFMA violations for inconsistency with the plan’s fire-management requirements and the old-forest standard; the district court granted summary judgment to the Forest Service.

## Issues

1. Whether the Project’s conversion of lands from MPC 5.2 to MPC 5.1 and its fire-management approach were inconsistent with binding forest-plan requirements in violation of NFMA.
2. Whether the Project violated NFMA by failing to comply with, or effectively nullifying, the plan’s binding old-forest standard, including by treating old forest as absent in the project area.

## Decision

- The Ninth Circuit affirmed in part and reversed in part the district court’s judgment.
- The court held the Forest Service’s fire-management direction and MPC conversion were consistent with the governing forest plan and did not violate NFMA.
- The court held the Project violated NFMA as to the old-forest standard because the Project’s analysis undermined a binding plan requirement and could not be reconciled with plan consistency.
- The case was remanded for further proceedings consistent with the court’s opinion.

## Legal Principles

- NFMA requires site-specific projects to be consistent with the governing forest plan.
- Forest-plan “standards” are mandatory and may not be disregarded or altered through project-level decisionmaking absent a plan amendment.
- Plan “guidelines” and desired-condition provisions provide administrative discretion, so long as project implementation remains within the bounds of binding standards.
- A project’s analytical baseline and resource characterization may violate NFMA where it effectively negates a quantitative or otherwise mandatory forest-plan standard.

## Conclusion

The Ninth Circuit sustained the Forest Service’s discretion to implement project-level fire and MPC management within plan constraints, but required strict compliance with the plan’s binding old-forest minimums, rejecting project analysis that functionally erased old forest for purposes of applying the forest plan’s standard.


Alliance for the Wild Rockies v. U.S. Forest Serv., 907 F.3d 1105 (9th Cir. 2018)