ELR Citation: 46 ELR 20065
No(s). 14-1807 (D.D.C. Mar 29, 2016) (Bates, J.)

A district court held that FWS violated NEPA when it reissued two orders authorizing the killing of double-crested cormorants in certain states. FWS issued an EA and FONSI for the orders rather than an EIS. But the EA is insufficient to justify FWS' FONSI because FWS did not take the requisite “ha...