Center for Biological Diversity and Idaho Conservation League v. United States Fish and Wildlife Service and The Army Corps of Engineers

CourtDistrict Court, D. Idaho
DecidedMarch 24, 2026
Docket2:25-cv-00710
StatusUnknown

This text of Center for Biological Diversity and Idaho Conservation League v. United States Fish and Wildlife Service and The Army Corps of Engineers (Center for Biological Diversity and Idaho Conservation League v. United States Fish and Wildlife Service and The Army Corps of Engineers) is published on Counsel Stack Legal Research, covering District Court, D. Idaho primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Center for Biological Diversity and Idaho Conservation League v. United States Fish and Wildlife Service and The Army Corps of Engineers, (D. Idaho 2026).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF IDAHO CENTER FOR BIOLOGICAL DIVERSITY and IDAHO CONSERVATION LEAGUE,

Plaintiffs, Case No. 1:25-cv-00710-DCN

v. MEMORANDUM DECISION AND ORDER UNITED STATES FISH AND WILDLIFE SERVICE and THE ARMY CORPS OF ENGINEERS,

Defendants.

I. INTRODUCTION Before the Court is the Center for Biological Diversity and Idaho Conservation League’s (“Plaintiffs”) Motion for Preliminary Injunction/Temporary Restraining Order. Dkt. 16. Plaintiffs argue a real estate developer’s violation of its Clean Water Act permit triggered statutory obligations which Defendants—the United States Fish and Wildlife Service and Army Corps of Engineers—have not fulfilled. Plaintiffs ask the Court to order Defendants to fulfil those obligations, and to enjoin construction until they do so. Because the Court finds Plaintiffs have not shown irreparable harm or a significant question on the merits, the Court DENIES the Motion. II. BACKGROUND The Idaho Club Lakeside Marina Development Project (“Project”) is a real estate redevelopment project on the shores of Lake Pend Orielle. The Project’s developer1 seeks

to replace a campground, RV park, and dilapidated marina with a residential community and new commercial marina. To comply with the requirements of the Clean Water Act, the developer sought a Clean Water Act § 404 permit from the Army Corps of Engineers (“Corps”). In addition to the standard Clean Water Act analysis, the permit application triggered the Corps’ statutory duties under the Endangered Species Act (“ESA”) and the

National Environmental Policy Act (“NEPA”). 1. ESA and NEPA Procedures Understanding the facts of this case requires a dive into the jargon-and-acronym- laden laws which provide our statutory backdrop. The ESA requires the Corps to ensure that granting the permit would not be “likely to jeopardize the continued existence of

any endangered species or threatened species or result in the destruction or adverse modification of [critical] habitat of such species . . . .” 16 U.S.C. § 1536(a)(2). ESA review usually begins when the action agency (here, the Corps) develops a Biological Assessment (“BA”) pursuant to 50 C.F.R. § 402.12. If the BA indicates the project is not likely to adversely affect any listed species (or any critical habitat of a listed species), the action

agency initiates “informal consultation” with the United States Fish and Wildlife Service (“FWS”).2 50 C.F.R. § 402.14(b)(1).

1 William Haberman, Valiant Idaho, LLC, and Valiant Idaho, LLC II. If FWS concurs in the action agency’s “not likely to adversely affect” conclusion, action agency can move forward. 50 C.F.R. § 402.13. If either the BA or FWS conclude

the project is likely to adversely affect a listed species or its critical habitat, the action agency must initiate formal consultation. 50 C.F.R. § 402.13(a). If, however, the action agency and FWS later agree the project is not likely to adversely affect a listed species or its critical habitat, the consultation is terminated. 50 C.F.R. § 402.14(m)(3). The action agency is required to reinitiate consultation, inter alia,

If new information reveals effects of the action that may affect listed species or critical habitat in a manner or to an extent not previously considered; [or] [i]f the identified action is subsequently modified in a manner that causes an effect to the listed species or critical habitat that was not considered in the biological opinion or written concurrence.

50 C.F.R. § 402.16(a)(2–3). Practitioners refer to these responsibilities collectively as “Section 7” obligations. NEPA, meanwhile, requires the Corps to assess the environmental effects proposed “major Federal actions,” including Clean Water Act permits. 42 U.S.C. § 4332(C); 33 C.F.R. Part 333. In the permitting context, the Corps distinguishes between two levels of review. Typically, the Corps begins its NEPA analysis with an Environmental Assessment (“EA”). 33 C.F.R. § 333.15. An EA alone usually satisfies the Corps’ NEPA obligations. 33 C.F.R. § 333.15(c).3 If the EA concludes the project is unlikely to have a significant

2 If the BA indicates the project may impact a listed marine species, the action agency must advise the United States Marine Fisheries Service. 50 C.F.R. § 402.1(b). But for freshwater and terrestrial species— the only species implicated here—the action agency is only required to consult with FWS. Id.

3 If the major Federal action will obviously have a significant environmental impact, 33 C.F.R. § 333.12(a)(4)(ii), or if the EA reveals that a significant impact is likely, 33 C.F.R. § 333.15(b)(iv), the Corps develops a more comprehensive Environmental Impact Statement (“EIS”). Cf. 33 C.F.R. § 333.21. impact, the Corps issues a Finding of No Significant Impact (“FONSI”). 33 C.F.R. § 333.16. Although NEPA sometimes requires supplemental analyses while major Federal

action is ongoing, Marsh v. Oregon Nat. Res. Council, 490 U.S. 360, 370–71 (1989), once the major Federal action is completed, NEPA obligations terminate, Norton v. S. Utah Wilderness All. (SUWA), 542 U.S. 55, 72–73 (2004). 2. Fact Background When the Corps received the developer’s permit application for the Project, it initiated ESA and NEPA review. Under the ESA, the Corps’ initial BA concluded the

Project was likely to adversely affect bull trout, a listed salmonid species in Lake Pend Orielle and its surrounding waterways. Dkt. 16-2. Critically for the present case, some of the Corps’ concerns related to bull trout’s presence in a manmade seasonal channel running through the marina construction site: the North Branch of Trestle Creek (“NBTC”). Dkt. 16-2, at 10. The permit application called for rerouting the NBTC from its existing channel

to a new path rejoining Trestle Creek. As the BA acknowledged, rerouting activities were to “be completed prior to the marina construction and during dry conditions in the NNTC between August and November.” Id.

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Center for Biological Diversity and Idaho Conservation League v. United States Fish and Wildlife Service and The Army Corps of Engineers, Counsel Stack Legal Research, https://law.counselstack.com/opinion/center-for-biological-diversity-and-idaho-conservation-league-v-united-idd-2026.