Case 2:21-cv-00161-RMP ECF No. 1 filed 05/12/21 PageID.1 Page 1 of 73 Claire Loebs Davis, WSBA #39812 Dakota Rash, WSBA #57299 (admission to ED WA pending) ANIMAL & EARTH ADVOCATES, PLLC 2226 Eastlake Ave E #101 Seattle, WA 98102 Tel: (206) 601-8476
[email protected] [email protected] Attorneys for Plaintiff IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF WASHINGTON KETTLE RANGE CONSERVATION GROUP, Case No. 2:21-cv-161 Plaintiff, COMPLAINT FOR DECLARATORY AND v. INJUNCTIVE RELIEF U.S. FOREST SERVICE, GLENN National Forest Management Act, CASAMASSA, Pacific NorthWest National Environmental Policy Act, Regional Forester, U.S. Forest Service, and Administrative Procedure Act RODNEY SMOLDON, Forest Supervisor, Colville National Forest, TRAVIS FLETCHER, District Ranger, Republic Ranger District, U.S. Forest Service. Defendants. COMPLAINT – 1 Case 2:21-cv-00161-RMP ECF No. 1 filed 05/12/21 PageID.2 Page 2 of 73 1 I. INTRODUCTION 2 1. Plaintiff Kettle Range Conservation Group (“KRCG” or “Plaintiff”) 3 challenges the final decision by the United States Forest Service (“Forest Service”) 4 to proceed With the Sanpoil Project (“the Project”), because of its failure to perform 5 a meaningful analysis of the environmental impacts of alloWing timber harvests, 6 controlled burns, and road work within 47,956 acres (the “Project Area”) of the 7 Colville National Forest (“Colville Forest” or “Forest”). KRCG also challenges the 8 Forest Service’s final decision approving the 2019 Colville National Forest Land 9 Management Plan (“2019 Forest Plan” or “Plan”), because it fails to protect old- 10 growth trees from logging through projects such as the Sanpoil Project.