following projects are cumulative actions that should have been identified and analyzed within the EIS: (1) the “Megram Roadside Hazard Tree Project;” (2) the “Happy Plantation Project;” (3) the “Phase 1” and “Phase 2” logging projects; (4) the “Plantation Precommericial Thinning, Release, and Fuels Treatment project;” and (5) the “Plantation Planting, Site Preparation, and Fuels Treatment project.” {See PI. Reply at 26.) In response, the Forest Service asserts that the EIS should be upheld because plaintiffs have failed to meet their burden to prove that the projects they identified have cumulative significant impacts. {See Def. Reply at 22.) The Forest Service, however, cannot shift to plaintiffs the responsibility of proving cumulative impact. See City of Carmel, 123 F.3d at 1161 (<HOLDING>); City of Davis v. Coleman, 521 F.2d 661, 671
recognizing a defendants connection to dc because the plaintiff had argued and provided correspondence between the parties demonstrating an ongoing relationship between the parties including the defendant giving the plaintiff directions regarding other business projects that the defendant intended to pursue and argued that the contract would have been at least partly performed within dc holding that affidavits are sufficient if they describe the justifications for nondisclosure with reasonably specific detail demonstrate that the information withheld logically falls within the claimed exemption and are not controverted by either contrary evidence in the record nor by evidence of agency bad faith holding that eis must provide a useful analysis of the cumulative impacts of past present and future projects holding that a cumulative impacts analysis was insufficient where the agency had examined single projects in isolation because there were several foreseeable similar projects in a geographical region that added to the cumulative impacts holding agency had burden to describe other area projects and detail the cumulative impacts of these projects