Oregon Natural Desert Association v. Singleton

In the 1980s, Congress designated portions of the Owyhee River as wild and scenic rivers under the Wild and Scenic Rivers Act (WSRA). Pursuant to the WSRA, in 1991, the Bureau of Land Management (BLM) (defendant) developed a comprehensive river-management plan (the plan) that included scenery, geology, recreation, wildlife, and cultural outstanding remarkable values (ORVs). An accompanying environmental assessment identified several negative effects from permitted livestock grazing that conflicted with multiple ORVs. To address grazing’s negative effects, the plan recommended an inventory of river areas to establish baseline grazing-level data and set grazing standards for maintaining and improving vegetation. By 1999, the baseline inventory had not been completed, and aside from closing one pasture, grazing levels were maintained at or above levels in place when the plan was released. In August 1999, a biologist recorded additional damage to portions of the river caused by grazing, such as trampled creek beds and stripped vegetation. A group of environmentalists (plaintiff) sued the BLM, seeking an injunction against grazing along the river. The Oregon Cattleman’s Association (defendant) intervened, representing ranchers with public grazing permits. At trial, the BLM provided evidence of the river corridor’s improved conditions, including evidence that 146.4 miles of the river had achieved properly functioning riparian conditions.