An agency must consider whether the action is related to other actions with individually insignificant but cumulatively significant impacts. 40 C.F.R. § 1508.27(b)(7). An agency must consider the cumulative impacts of each action, “when added to other past, present and reasonably foreseeable future actions regardless of what agency (federal or nonfederal) or person undertakes such other actions.” Muckleshoot Indian Tribe v. United States Forest Serv., 177 F.3d 800, 814 (9th Cir. 1999) (environmental impact statement (EIS) was inadequate); cf. Neighbors of Cuddy Mountain v. United States Forest Serv., 137 F.3d 1372, 1379 (9th Cir. 1998).
Further, an...
