Natural Resources Defense Council v. Hodel

The Federal Land Policy and Management Act of 1976 (land-management act) gave the Bureau of Land Management (bureau) (defendant) authority to set public land-management policy. The Public Rangeland Act (rangeland act) refined the land-management act’s provisions for range management and called for rangeland improvements to remedy the degradation of rangeland conditions and to curb overgrazing. The bureau prepared a draft environmental-impact statement to compare a proposed action and several alternatives for improving rangeland conditions to be included in the bureau’s management-framework plan for the Reno, Nevada, area. The management-framework plan was the final land-use plan for grazing in the Reno area. Without providing a timetable or exact detail on how it would set grazing capacity on overgrazed rangeland, the bureau set broad objectives in the management-framework plan to remedy the problem of overgrazing and improve rangeland quality. In developing the management-framework plan, the bureau chose to install range improvements and grazing systems for the rangeland that needed the most improvement. The management-framework plan called for a significant reduction in livestock numbers over time to improve the rangeland’s quality. Neither the draft environmental-impact statement nor the management-framework plan contained the type of detailed information that would be required in the grazing permits to be issued pursuant to the management-framework plan. In other words, the environmental-impact statement and the management-framework plan lacked site-specific estimates of future grazing capacity and instead provided for methods to achieve the rangeland act’s goals for range management and the rangeland improvement only in general terms. The Natural Resources Defense Council (NRDC) (plaintiff) sued the bureau, claiming that the environmental-impact statement and management-framework plan were insufficiently specific to satisfy the mandate of the rangeland act to improve public rangelands. The NRDC argued that the mandate of the rangeland act called for more immediate and specific reductions in livestock grazing in the management-framework plan to ensure improvements in rangeland quality in the Reno area. The bureau moved for summary judgment.