West Camas Creek. Since both sales affect the West Camas Creek watershed, ISC contends that the Forest Service is obligated to supplement its EA with an EIS to account for the cumulative impacts of the two sales. In Save the Yaak Comm. v. Block, we concluded that when agency projects have the potential for cumulative harm an “assessment of connected actions is necessary even if the impact of the proposed action is not significarit.” 840 F.2d 714, 720 (9th Cir.1988). However, our decision in Yaak does not mandate the creation of a supplemental EIS or EA in all eases. See id. The standard for a supplemental EA and EIS is whether there have been “significant changes in the proposed action.” Price Rd. Neighborhood Ass’n v. United States Dept, of Transp., 113 F.3d 1505, 1509 (9th Cir.1997) (<HOLDING>). While the Miners Creek EA did not address the
holding that the standard for supplementing an ea is the same as for an eis holding that the standard for a motion for judgment on the pleadings is the same as the standard for a motion to dismiss holding the standard for obtaining a coa is the same as for a cpc holding that the standard of review for the sufficiency of the evidence is the same as the standard for denying a motion for a directed verdict holding that the standard of review for an award of statutory damages is even more deferential than an abuse of discretion standard