Friends of the Boundary Waters Wilderness v. Dombeck

The Boundary Waters Canoe Area (canoe area) was a wilderness area managed by the federal government. The United States Congress enacted the Wilderness Act of 1964 (wilderness act) to protect and preserve federal wilderness areas. The wilderness act generally prohibited the use of motorboats in wilderness areas, but the act allowed the continuance of previously established motorboat use in the canoe area. In 1978, Congress enacted the Boundary Waters Canoe Area Wilderness Act (canoe-area act). The canoe-area act modified the wilderness act, restricting motorboat use to specific areas and setting quotas for such use. The United States Forest Service (service) (defendant) established quotas for motorboat use in its wilderness plan. The service explained that it set the motorboat quotas pursuant to the canoe-area act and that motorboat use had begun to strain the wilderness environment. The service reasoned that the quota was necessary to implement the goals of the canoe-area act and the wilderness plan, which were to maintain the naturalness of the canoe area and protect it for future generations. The service had implemented its decision regarding motorboat quotas with the guidance from the environmental-impact statement it had prepared, pursuant to the National Environmental Policy Act (NEPA), for the implementation of its wilderness plan. A group of outfitters (plaintiffs), or wilderness guides, challenged the validity of the motorboat quota in the wilderness plan because it caused them economic losses. The outfitters claimed that the environmental-impact statement, which guided the service’s decision to institute the motorboat quota, violated NEPA because it failed to consider the quota’s economic impact as required by NEPA. The district court granted summary judgment in favor of the service, finding that the outfitters lacked standing because economic loss was not a protected interest under NEPA. The outfitters appealed.