Idaho Watersheds Project v. Hahn

The Bureau of Land Management (bureau) (defendant) was responsible for managing the Owyhee Resource Area (Owyhee area). In 1981, the bureau prepared an environmental-impact statement, pursuant to the National Environmental Policy Act (NEPA), to evaluate the environmental effects of cattle grazing in the Owyhee area. The bureau found that nearly all the rangeland and streams in the Owyhee area were in poor or merely fair condition due to overgrazing. In 1995, major changes were made to regulations regarding cattle grazing, including a new requirement that cattle ranchers undergo an annual reauthorization of their grazing permits. In 1996, the bureau found that nearly all the streams in the Owyhee area were in unsatisfactory condition. In 1997, the bureau issued 68 grazing permits to cattle ranchers. The bureau filled out preprinted one-page forms for each permit. Each form stated that the corresponding permit complied with the 1981 environmental-impact statement in an effort by the bureau to comply with NEPA requirements. The Idaho Watersheds Project (watersheds project) (plaintiff) sued the bureau, alleging violations of NEPA, among other claims. A group of ranchers (defendants) intervened in the proceeding. In granting partial summary judgment in favor of the watersheds project, the district court found that the bureau had violated NEPA because the bureau had not prepared any new environmental-impact statements prior to issuing the 68 grazing permits. The district court conducted additional proceedings in which it took recommendations from a rangeland-management specialist from the bureau. The district court issued a permanent injunction that required the bureau to conduct an environmental review of the 68 permits pursuant to NEPA. The bureau had indicated that it would take six years to complete the required environmental studies required under NEPA, so the district court imposed interim measures pursuant to the specialist’s recommendations to protect the environment in the Owyhee area while the bureau conducted its environmental reviews. The district court reasoned that interim measures were necessary to prevent additional environmental harm during the six-year review period because overgrazing had already been damaging the environment for 15 years since the last environmental assessment of grazing. The ranchers appealed the issuance of the injunction, arguing that the district court could not order the bureau to perform discretionary duties by granting mandamus relief.