The Fund for Animals v. Norton

294 F. Supp. 2d 92 (2003)

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The Fund for Animals v. Norton

United States District Court for the District of Columbia
294 F. Supp. 2d 92 (2003)

Facts

In 1963, snowmobiles were first permitted in national parks such as Yellowstone National Park, Grand Teton National Park, and the John D. Rockefeller, Jr. Memorial Parkway (collectively, the parks). Snowmobile usage eventually reached a peak of 1,700 snowmobiles in the parks per day on the highest-usage days. The Organic Act, which created the National Park Service (park service), mandated that the park service always seek to minimize adverse impacts on park resources and to favor conserving natural resources over the public enjoyment of such resources. The Park Service Yellowstone Act mandated that the park service prevent injury to the parks and wildlife. In the winter of 1996–1997, the park service observed a negative impact on bison caused by the trails created for snowmobile use. In May 1997, the Fund for Animals (the fund) (plaintiff) sued the park service for violating the National Environmental Policy Act (NEPA). The fund alleged that the park service’s winter-use plan permitting trail grooming and snowmobile use required an environmental-impact statement. As a result, in November 2000, the park service released an environmental-impact statement and corresponding record of decision (2000 decision), which allowed snowmobile use to continue temporarily. In December 2000, the park service issued a proposed rule that completely phased out snowmobile use over several years in favor of snowcoach use. Snowcoaches were determined to be a much more environmentally favorable method of transportation through the parks. In January 2001, the day after President Bush took office, the final rule (snowcoach rule) was published. The new administration immediately stayed the snowcoach rule pending a review. The International Snowmobiler Manufacturers Association, among others, challenged the 2000 environmental-impact statement and 2000 decision, seeking that the 2000 decision and the snowcoach rule be set aside. Ultimately, the snowcoach rule’s implementation was delayed. In 2003, the park service issued a record of decision (2003 decision), which permitted 950 snowmobiles to enter the parks each day. The fund and the Greater Yellowstone Coalition (plaintiff) sued the park service, arguing that the 2003 decision to allow continued snowmobile usage was arbitrary and capricious and in violation of the conservation mandates of the statutes governing the park service’s administration of the parks.

Rule of Law

Issue

Holding and Reasoning (Sullivan, J.)

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