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Sawtooth Mountain Ranch LLC v. United States Forest Service

ELR Citation: 49 ELR 20108
Nos. 1:19-cv-0118-CWD, (D. Idaho, 06/13/2019) (Dale, M.J.)

A magistrate judge declined to preliminarily enjoin the U.S. Forest Service from constructing a recreational trail across private property located in the Sawtooth National Recreation Area. The property owners argued the Service's decision to proceed via a categorical exclusion was in violation of NEPA, because certain ground-disturbing actions comprising the trail project—constructing trailheads, converting existing roads and other rights-of-way to trail segments—fell outside the categorical exclusion for trail construction. But the magistrate judge found the Service presented a rational connection between the facts and its conclusion that these actions fit within the scope of the exclusion, and thus that the property owners failed to demonstrate that the Service's decision to proceed was arbitrary and capricious. The property owners also argued the Service's decision violated NEPA by failing to adequately analyze the effects of the ground-disturbing actions to construct the trail and failing to sufficiently explain its conclusion that the effects upon wetlands would be insignificant. But the magistrate judge again found the Service considered relevant factors and provided a reasoned decision consistent with analyses and findings during the scoping process. The magistrate judge therefore denied the owners' motion for preliminary injunction.