NCRA seems to be on fairly good legal ground based on precedent. But every time you go to court it's a ****shoot so no guarantees especially when it comes to the great CEQA.

There's a difference between "piecemealing" and proper scoping of the project for CEQA purposes. The EIR that was done (which according to some court decisions didn't have to be) covers what there was any hope (even remote) of money to work on. The actual money only covered a small portion of that (Windsor to Napa Jct.).

There is no realistic hope of money to resurrect the line north of Willits, and IMO north of Cloverdale, because there is no hope of enough traffic out there (unless the pot farmers start shipping by rail?) to even cover the cost of ordinary maintenance and operation let alone the inevitable storm and earthquake damage. The environmental cleanup cost of officially abandoning it would be as much as or more than rebuilding the railroad (and cleanup might require rebuilding the railroad temporarily to haul everything out). No money for that either. So it sits unused and unabandoned and whatever is left (and not brushed out occasionally by speeder groups) rots. If the enviros and their pet trail groups were willing to take the property as-is and assume responsibility for cleanup (let them pay the scrap value of whatever's out there plus a penny for the property?) they might get a fairer hearing at NCRA and its funding sources.

Is NCRA really a state agency? What legislation set it up and how are the Board members selected? Is the Board appointed by the state or is it local government and other local representatives? I did a little digging but haven't come up with a clear statement - probably just not in the right place yet. I don't trust a newspaper article apparently written for them by the enviros to get that right.

Does WA have to prepare SEPA documents for whatever it does on the eastern WA lines, or just NEPA as administered by FRA? Suspect not. Pretty good precedent either way.