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JOY ROAD AREA FOREST AND WATERSHED ASSn.v. CA DEPT. OF FORE. PART -II
Trial court correctly found that Department of Forestry & Fire Protection abused its discretion by approving a timber harvest plan where plan's cumulative impact analysis with regard to the issue of fog drip lacked any facts, statistics, reports, or studies supporting contention that decrease in fog drip from trees would not result in a decrease in the water supply; plan lacked cumulative impact analysis addressing impact of future housing development in harvest area, but housing development was a reasonably foreseeable consequence of proposed harvest; additional information about northern spotted owl that was added to plan during review process was sufficiently significant to merit notice and recirculation; and U.S. Fish and Wildlife Service had not approved project as required by department's own regulation.

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