Natural Resources Defense Council v. Morton
United States District Court for the District of Columbia
388 F. Supp. 829 (1974), aff'd per curiam, 527 F.2d 1386, cert. denied, 427 U.S. 913 (1976)
- Written by Robert Cane, JD
Facts
The Bureau of Land Management (bureau) (defendant) managed over 171 million acres of public land. The bureau administered about 24,000 licenses, permits, and leases for livestock grazing on bureau-managed land. Pursuant to the National Environmental Policy Act (NEPA), the bureau prepared a programmatic environmental-impact statement covering its entire livestock-grazing program. The programmatic environmental-impact statement was intended to provide an overview of the cumulative environmental impact of the bureau’s livestock-grazing program and serve as the foundation for environmental analyses and supplemental environmental-impact statements for specific grazing-management actions. However, the bureau provided no guidance regarding what circumstances called for the preparation of supplemental environmental-impact statements. Further, the proposed programmatic environmental-impact statement did not include a detailed analysis of local geographic conditions relevant to specific areas and provided citizens an opportunity to comment on only the programmatic environmental-impact statement, rather than allowing local input. The Natural Resources Defense Council (NRDC) (plaintiff) filed suit against the bureau. The NRDC claimed that the bureau failed to comply with NEPA in its issuance of renewed grazing permits over the past four years and would continue to fail to comply with NEPA because it had not prepared and will not prepare environmental-impact statements analyzing the actual environmental impacts of grazing on specific local environments. Evidence indicated that 84 percent of grazing land under management of the bureau was in fair, poor, or bad condition and that bureau-managed land had seriously deteriorated. The NRDC sought declaratory relief that the bureau’s programmatic environmental-impact statement was not sufficient to comply with NEPA and that the bureau must assess the specific environmental effects of permits issued.
Rule of Law
Issue
Holding and Reasoning (Flannery, J.)
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