Southern Utah Wilderness Alliance v. National Park Service

The Salt Creek Canyon supported an extensive ecosystem in Canyonlands National Park. The Salt Creek Road was an unpaved trail that ran in and out of Salt Creek. The National Park Service (NPS) (defendant) restricted vehicle use in Salt Creek Canyon above the Peekaboo campsite according to the 1916 National Park Service Organic Act (the Organic Act). The Organic Act mandated that the NPS provide for the conservation and enjoyment of scenery and natural historic objects and wildlife therein in a manner that “will leave them unimpaired for future generations to enjoy.” In 2001, the NPS commenced a revision of its management policies and defined “impairment” prohibited by the Organic Act as an impact that would harm the integrity of the park resources or values, including the opportunities that otherwise would be present for the enjoyment of those resources or values. Whether an impact would meet this definition was based on the timing, severity, and effects of the impact. An environmental assessment (EA) was conducted in 2002, which analyzed the impacts of vehicle travel in Salt Creek. The NPS examined several alternatives but decided on a preferred alternative that prohibited all motor-vehicle travel. In 2004, the NPS issued a final rule that amended the regulations for Canyonlands by adopting the preferred alternative and prohibiting motor vehicles on Salt Creek Road above the Peekaboo campsite. Utah Shared Access Alliance and other interested groups (USA-ALL) (plaintiffs) claimed that the NPS’s 2001 management policies misinterpreted the Organic Act and that NPS’s final rule violated the Organic Act because it deprived the public of its ability to use and enjoy significant portions of Canyonlands. USA-ALL filed an administrative appeal of the final rule.