Sierra Club v. United States

23 F. Supp. 2d 1132 (1998)

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Sierra Club v. United States

United States District Court for the Northern District of California
23 F. Supp. 2d 1132 (1998)

Facts

In 1980, the National Park Service (park service) (defendant) established its 1980 General Management Plan (general plan) regarding the management and development of Yosemite National Park (park). The general plan was later amended by the 1992 Concession Services Plan (concessions plan). Both the general plan and the concessions plan called for a broad approach to managing and developing the park. Both plans contemplated future construction within the park in general terms. Further, both plans were adopted after the preparation of environmental-impact statements pursuant to the National Environmental Policy Act (NEPA). More recently, the park service engaged in two major planning projects that covered the whole park regarding the construction of new lodging for visitors and employee housing. Both planning projects involved the preparation of environmental-impact statements. Further, the project plans rejected a piecemeal approach to development within the park and promoted a comprehensive view of implementing the general plan. In January 1997, a flood destroyed much of the public-lodging facilities and employee housing at the base of Yosemite Falls. The park service quickly developed a plan to build new facilities for public lodging that would have resulted in substantial structural changes to the area. In April 1997, the park service drafted an environmental assessment and subsequently issued a Finding of No Significant Impact (FONSI) regarding the new lodging-development plan. The park service did not seriously consider alternatives to building new lodging near the area that was flooded. The Sierra Club (plaintiff) challenged the park service’s new lodging-development plan and moved for a preliminary injunction, arguing that the park service had neither considered the cumulative impact of its new lodging-development plan nor properly considered several reasonable alternatives to the plan that might have had a lesser environmental impact.

Rule of Law

Issue

Holding and Reasoning (Breyer, J.)

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