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WildEarth Guardians v. Zinke

368 F. Supp. 3d 41 (2019)

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WildEarth Guardians v. Zinke

United States District Court for the District of Columbia

368 F. Supp. 3d 41 (2019)

Facts

The Bureau of Land Management (BLM) (defendant) authorized 282 oil-and-gas leases on federal land in Wyoming. The environmental assessments supporting the BLM’s decision discussed climate change on a conceptual level, summarizing Wyoming’s current climate, explaining the mechanics of climate change, acknowledging that oil-and-gas drilling contribute to climate change, and predicting the impact of climate change on Wyoming’s climate. However, the environmental assessments did not quantify or forecast drilling-related greenhouse-gas emissions, nor did they evaluate the potential greenhouse-gas emissions from the downstream use of oil and gas produced on the leased parcels of land. Further, the environmental assessments did not compare the cumulative impacts of drilling on the leased parcels to state, regional, and national greenhouse-gas-emissions forecasts. Based on the environmental assessments, the BLM issued Findings of No Significant Environmental Impacts (FONSIs), concluding that the leases could be authorized without an environmental-impact statement. WildEarth Guardians (plaintiff) and Physicians for Social Responsibility (plaintiff) challenged the BLM’s authorization of the leases, arguing that the BLM had violated the National Environmental Policy Act of 1969 (NEPA) by failing to adequately quantify the leases’ climate-change impact. The BLM argued that it was impossible to adequately predict the impact of greenhouse-gas emissions from oil-and-gas drilling at the regional level and that it was premature to require an in-depth emissions analysis at the leasing stage of the oil-and-gas development framework because it was impossible to determine whether an approved parcel would ultimately be explored or developed.

Rule of Law

Issue

Holding and Reasoning (Contreras, J.)

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