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WildEarth Guardians v. Montana Snowmobile Association

United States Court of Appeals for the Ninth Circuit

790 F.3d 920 (2015)

Facts

Executive Order 11644 and the 2005 Travel Management Rule (TMR) required the United States Forest Service (the Forest Service) (defendant) to consider certain criteria, called minimization criteria, in choosing areas within national forests to permit outdoor-recreational-vehicle (ORV) use. The Forest Service issued a revised forest plan (the revised plan) for the Beaverhead-Deerlodge National Forest, designating several areas within the forest for snowmobile use. The environmental-impact statement (EIS) supporting the adoption of the revised plan contained a forest-wide analysis that concluded that the plan met the required minimization criteria. However, the EIS did not include an analysis of the minimization criteria for each individual area within the forest to be designated for snowmobile use, nor did the EIS refer to the specific criteria contained in the TMR. WildEarth Guardians and other groups (plaintiffs) challenged the adoption of the revised plan, arguing that the EIS analysis had failed to properly apply the minimization criteria. The district court found that the EIS analysis was sufficient and granted summary judgment in favor of the Forest Service. WildEarth Guardians appealed.

Rule of Law

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Issue

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Holding and Reasoning (Paez, J.)

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