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The FS NEPA Handbook states:

1909.15 FSH § 14.1 No Action Alternative

	The no action alternative provides a baseline for estimating the effects of
other alternatives; therefore, consider the no  action alternative in detail
in each environmental analysis.

	Two distinct interpretations of no action are often possible. The first
interpretation involves an action such as the amendment or revision of a
Forest Land and Resource Management Plan where ongoing programs described
within the existing plan continue, even as new plans are being developed. In
these cases, the no  action alternative means no change from current
management direction. Consequently, the responsible official would compare
the projected impacts of alternative management schemes to those impacts
projected for the existing plans.

The second interpretation of no action is that no action or activity would
take place, such as when a proposed road construction project would be
cancelled. The nature and scope of the proposed action will aid the
responsible official in determining which interpretation is appropriate to
the analysis.

	For further guidance see question 3 in section 65.12 of CEQ’s 40 Most Asked
Questions.

The CEQ's 40 Questions state:

3. NoAction Alternative.

Q.  What does the “no action” alternative include? If an agency is under a
court order or legislative command to act, must the EIS address the “no
action” alternative?

A. Section 1502.14(d) requires the alternatives analysis in the EIS to
“include the alternative of no action.” There are two distinct
interpretations of “no action” that must be considered, depending on the
nature of the proposal being evaluated. The first situation might involve an
action such as updating a land management plan where ongoing programs
initiated under existing legislation and regulations will continue, even as
new plans are developed. In these cases “no action” is “no change” from
current management direction or level of management intensity. To construct
an alternative that is based on no management at all would be a useless
academic exercise. Therefore, the “no action” alternative may be thought of
in terms of continuing with the present course of action until that action
is changed. Consequently, projected impacts of alternative management
schemes would be compared in the EIS to those impacts projected for the
existing plan. In this case, alternatives would include management plans of
both greater and lesser intensity, especially greater and lesser levels of
resource development.

The second interpretation of “no action” is illustrated in instances
involving federal decisions on proposals for projects. “No action” in such
cases would mean the proposed activity would not take place, and the
resulting environmental effects from taking no action would be compared with
the effects of permitting the proposed activity or an alternative activity
to go forward.

Where a choice of “no action” by the agency would result in predictable
actions by others, this consequence of the “no action” alternative should be
included in the analysis. For example, if denial of permission to build a
railroad to a facility would lead to construction of a road and increased
truck traffic, the EIS should analyze this consequence of the “no action”
alternative.

In light of the above, it is difficult to think of a situation where it
would not be appropriate to address a “no action” alternative. Accordingly,
the regulations require the analysis of the no action alternative even if
the agency is under a court order or legislative command to act. This
analysis provides a benchmark, enabling decisionmakers to compare the
magnitude of environmental effects of the action alternatives. It is also an
example of a reasonable alternative outside the jurisdiction of the agency
which must be analyzed. Section 1502.14(c). See Question 2 above. Inclusion
of such an analysis in the EIS is necessary to inform the Congress, the
public, and the President as intended by NEPA. Section 1500.1(a).


I think there are good arguments that the no logging alternative is
required.  I can send you what I agrue in appeals.


>
>=====  A message from the 'appealist' discussion list  =====
>
>Has anyone had experience appealing or litigating based on a No-Action
>alternative actually being an action alternative. I am preparing such an
>argument for the Quincy FEIS and ROD. The "no-action" alternative in this
>case is business as usual, i.e. following the current plans. The USFS
>argues that those plans would entail logging, but no actual site-specific
>logging projects are authorized by the plan. So, I would argue the
>no-action should be literally no-action, no logging.
>
>This line of argument is a little convoluted, but I wondered if anyone had
>legal cites, where a no-action alternative was actually found to not be
such.
>
>
>***Please note new e-mail address: bbird@newmexico.com***
>
>Bryan Bird
>Forest Conservation Council
>P.O. Box 22488
>Santa Fe, NM 87505-2488
>PH:  505.989.7446
>FAX: 505.954.4205
>
>