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WildEarth Guardians v. Bureau of Land Management

ELR Citation: 44 ELR 20069
Nos. 1:11-cv-1481, (D.D.C., 03/31/2014) (Leon, J.)

A district court held that environmental groups' NEPA and FLPMA claims against BLM in connection with its decision to lease two coal tracts in Wyoming's Powder River Basin lack merit. The groups alleged that BLM violated the statutes because the agency failed to adequately consider the impacts on local air quality and climate change resulting from the two leases before deciding to authorize the leases. In its memorandum opinion, the court held that the groups had standing to pursue their air quality and climate change claims. Nevertheless, the court denied the groups' motion for summary judgment. The groups raised several challenges to the sufficiency of BLM's EIS, but the essence of their complaint is that BLM did not analyze certain issues in the manner or level the groups would have preferred. The applicable standard of review simply does not allow that type of judicial second-guessing of agency decisionmaking. And the groups failed to point to any legal authority supporting their claim that BLM has a "duty" to ensure that its leasing decisions would result in federal air quality standards.