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CLUB v. CALIFORNIA DEPARTMENT OF FORESTRY AND FIRE PROTECTION
Substantial evidence supported a fair argument that timberland conversion project may have a significant effect on the environment, thus requiring preparation of an environmental impact report, where record contained detailed comment letter by an experienced professional plant ecologist and botanist opining that the mitigated project may have significant environmental effect in numerous specific areas including increased sediment due to erosion, the potential of net reduction in groundwater discharges due to irrigation, and permanent loss of 63 acres of spotted owl habitat.

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