American Motorcyclist Ass'n v. Watt

543 F. Supp. 789, 17 ERC 2204, 12 Envtl. L. Rep. (Envtl. Law Inst.) 21064, 17 ERC (BNA) 2204, 1982 U.S. Dist. LEXIS 17813
CourtDistrict Court, C.D. California
DecidedJuly 1, 1982
DocketCV 80-5561 AWT, 80-5599 AWT, 80-5629 AWT, 81-489 AWT and 81-1445 AWT
StatusPublished
Cited by13 cases

This text of 543 F. Supp. 789 (American Motorcyclist Ass'n v. Watt) is published on Counsel Stack Legal Research, covering District Court, C.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
American Motorcyclist Ass'n v. Watt, 543 F. Supp. 789, 17 ERC 2204, 12 Envtl. L. Rep. (Envtl. Law Inst.) 21064, 17 ERC (BNA) 2204, 1982 U.S. Dist. LEXIS 17813 (C.D. Cal. 1982).

Opinion

*791 MEMORANDUM OPINION

TASHIMA, District Judge.

This matter is before the Court on cross-motions for partial summary judgment by plaintiffs and certain of the defendants in one of the above-captioned cases: California Native Plant Society v. Watt, No. CV 81-489 AWT. 1 California Native Plant, like each of these consolidated eases, calls into question the validity of the California Desert Conservation Area Plan (the “Plan”), which was prepared by the Bureau of Land Management (“BLM”) pursuant to Section 601 of the Federal Land Policy and Management Act of 1976 (“FLPMA”), 43 U.S.C. § 1781. The Plan, and the procedure by which it was developed, were discussed extensively by this Court in an earlier opinion. American Motorcyclist Ass’n v. Watt, 534 F.Supp. 923 (C.D.Cal.1981) (denying request for preliminary injunctive relief by plaintiffs in certain of the other cases). 2 In the interest of brevity, that discussion will not be repeated here.

The primary issue raised in the present motions relates to the “Motorized-Vehicle Access” element (the “MVA element”) of the Plan. That element sets forth, among other things, restrictions on motorized vehicle use in those portions of the California Desert Conservation Area (“CDCA”) designated by the Plan as “Class L” areas. In particular, the MVA element specifies that motorized vehicles will be allowed only on “approved routes of travel” in Class L areas, and sets forth specific criteria by which such routes are to be selected. 3

Plaintiffs seek a declaration that these route selection criteria for Class L areas are inconsistent with the provisions of 43 C.F.R. § 8342.1, a BLM regulation promulgated pursuant to the authority of FLPMA and certain other statutes, 4 and with Exec. Order No. 11,644 (“E.O. 11,644”), 3 C.F.R. § 332 (1974), as amended by Exec. Order No. 11,989 (“E.O. 11,989”), 3 C.F.R. § 120 (1978). Plaintiffs further request that the Court enjoin federal defendants (James G. Watt, Secretary of the Interior, and various officials of the BLM) from approving routes of travel using the criteria contained in the Plan, and ask for a writ of mandate compelling those defendants to revise the Plan so as to make it consistent with applicable executive orders and regulations.

In their cross-motion for summary judgment, federal defendants ask for a declaration that the challenged route approval criteria are consistent with applicable law. 5

*792 After hearing argument and reviewing the extensive record pertinent to these motions, I have concluded, for the reasons hereinafter stated, that plaintiffs are entitled to summary judgment, and that limited declaratory and injunctive relief should be granted. In essence, both 43 C.F.R. § 8342.1 and E.O. 11,644 require that routes for off-road vehicles (“ORVs”) be selected so as to minimize adverse environmental effects. As will be elaborated below, I conclude that the criteria in the Plan are inconsistent with 43 C.F.R. § 8342.1, in that they allow for route approval without minimization of adverse environmental impacts. Under these circumstances, it is unnecessary to determine whether the provisions of E.O. 11,644 would also justify granting the relief sought by plaintiffs. 6

DISCUSSION

I. STANDING

The plaintiffs in this action are the California Native Plant Society, the Sierra Club, the Desert Tortoise Council, the San Bernardino Valley Audubon Society and the Wilderness Society. Since the issue has not previously been determined as to these plaintiffs, as a threshold matter, it is necessary to determine which, if any, of these plaintiffs have standing to challenge the route designation criteria for Class L areas contained in the Plan. The principles applicable to an analysis of that issue, in the context of this case, are fully discussed in AMA at 930-33. 7

With the exception of the Desert Tortoise Council, each of the plaintiffs has demonstrated “injury in fact.” Each has shown that application of the challenged motorized-vehicle route designation standards will cause environmental injury to Class L areas, that its members use the affected portions of the desert for recreation or study and that their use of the desert for those purposes would be impaired if the route approval criteria contained in the Plan were put into effect. Furthermore, plaintiffs have shown that the relief they seek, i.e., compliance with 43 C.F.R. § 8342.1 and E.O. 11,644, would redress their injury by reducing environmental impacts and the resultant impairment of recreational values.

Plaintiff Desert Tortoise Council, however, has asserted only that its members “are concerned over impacts on desert tortoise habitat” due to threatened route designations using the approval criteria contained in the Plan and that “[t]he loss of desert habitat will severely impair the ability of Desert Tortoise Council members to enjoy the resources of the California desert.” (Deck of David W. Stevens, filed Nov. 20, 1981.) The organization has made no showing that its members presently use the lands in Class L areas, or that they have specific plans to do so in the near future. In short, the Desert Tortoise Council has failed to show that it or its members have “personally suffered some actual or threatened injury” as a result of the conduct of defendants. As the Supreme Court made clear in Sierra Club v. Morton, 405 U.S. 727, 738-40, 92 S.Ct. 1361, 1367-68, 31 L.Ed.2d 636 (1972), an organizational plaintiff such as the Desert Tortoise Council must demonstrate “individualized injury” to itself or its *793 members, rather than a mere “organizational interest in the problem.” Since the Desert Tortoise Council has failed to show injury in fact of the type necessary to satisfy the case or controversy requirement of Art. Ill, it must be dismissed for lack of subject matter jurisdiction.

Plaintiffs have asserted environmental and recreational interests which are clearly within the “zone of interests” of FLPMA, and 43 C.F.R. § 8342.1

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543 F. Supp. 789, 17 ERC 2204, 12 Envtl. L. Rep. (Envtl. Law Inst.) 21064, 17 ERC (BNA) 2204, 1982 U.S. Dist. LEXIS 17813, Counsel Stack Legal Research, https://law.counselstack.com/opinion/american-motorcyclist-assn-v-watt-cacd-1982.