Fallon Paiute-Shoshone Tribe v. U.S. Department of the Interior

CourtDistrict Court, D. Nevada
DecidedJanuary 14, 2022
Docket3:21-cv-00512
StatusUnknown

This text of Fallon Paiute-Shoshone Tribe v. U.S. Department of the Interior (Fallon Paiute-Shoshone Tribe v. U.S. Department of the Interior) is published on Counsel Stack Legal Research, covering District Court, D. Nevada primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Fallon Paiute-Shoshone Tribe v. U.S. Department of the Interior, (D. Nev. 2022).

Opinion

1 2 3 4 5 6 UNITED STATES DISTRICT COURT 7 DISTRICT OF NEVADA 8 9 FALLON PAIUTE-SHOSHONE TRIBE and ) the CENTER FOR BIOLOGICAL DIVER- ) 10 SITY, ) ) ) 3:21-cv-00512-RCJ-WGC 11 Plaintiffs, )

) ORDER 12 vs. ) ) 13 U.S. DEPARTMENT OF THE INTERIOR, et ) al., ) 14 ) Defendants, ) 15 ) and ) 16 ) ORMAT NEVADA INC., ) ) 17 ) Defendant-Intervenor ) 18

19 Plaintiffs moved the Court for a temporary restraining order and a preliminary injunction 20 to bar construction of an approved geothermal facility. (ECF Nos. 13 & 14). At the hearing on 21 Plaintiffs’ motion, the Court granted in part and denied in part. The Court issued an order tempo- 22 rarily restraining and preliminarily enjoining Defendants and Ormat Nevada Inc. (“Ormat”) from 23 conducting the work described in the Decision Record for the Dixie Valley Geothermal Utilization 24 Project (“Project”) for 90 days, including implementation of the Aquatic Resources Monitoring 1 and Mitigation Plan (“ARMMP”). (ECF No. 31.) By this order, the Court denies Plaintiffs’ motion 2 for a preliminary injunction beyond 90 days. 3 FACTUAL BACKGROUND 4 The Bureau of Land Management (“BLM”) approved Ormat’s application to construct the 5 Project in November 2021, finding that the Project would result in no significant impact on the 6 environment and thereby avoiding the need for an Environmental Impact Statement (“EIS”). (ECF 7 No. 13-23, Decision Record (“DR”) at 4-21.) The Project, which consists of geothermal production 8 and injection wells, a power plant facility, and an electrical transmission line, is to be constructed 9 in Dixie Valley, about 43 miles northeast of Fallon, Nevada. (ECF No. 13-25, Final Environmental 10 Assessment (“EA”) at 1-1.) Defendants contend the binary technology for the plant does not con- 11 sume any groundwater or geothermal resource fluid, and subsurface aquifer pressures are main- 12 tained. (EA at 2-16; ECF No. 24-1, Second Declaration of Paul Thomsen ¶ 4). Construction would

13 take place in an area of existing development, including a pre-existing power line, roads, mineral 14 materials site, and numerous geothermal wells. (Id. at 3-113; ECF No. 6-1, Declaration of Paul 15 Thomsen ¶ 10.) The specific configuration of the Project has been changed several times during 16 the six-year environmental review process to accommodate Plaintiffs’ concerns regarding impacts 17 to nearby springs in Dixie Valley, including moving the location of one of the power plants and 18 the transmission line specifically to address viewshed concerns. (ECF No. 13-15 at 3-114, 3-126.) 19 The Dixie Meadows Hot Springs are used by members of Plaintiff Fallon Paiute-Shoshone 20 Tribe (the “Tribe”) for ceremonial and religious purposes. (Id. at 3-119.) In consultation with the 21 Tribe, BLM designated the Dixie Meadows Hot Spring as eligible for listing on the National Reg- 22 ister of Historic Places. (Id. at 3-118 to 3-119.) BLM asserted at hearing that the location of the

23 power plant is not within the designated sacred site. Transcript of Jan. 4, 2022 Hearing, at 42:13- 24 16, 44:5-11 (hereinafter, “Tr.”). The Tribe disputes this and claims that the sacred site extends to 1 uplands surrounding the springs. (Tr. 76:6-8.) In addition, the Dixie Valley toad, a species that is 2 not listed as endangered or threatened but whose listing determination is currently pending, is 3 found within wetlands fed from artesian springs on the western edge of the Dixie Valley playa. 4 (ECF No. 13-25 at 3-77.)1 Plaintiffs allege that both the Tribe’s religious practice and the Dixie 5 Valley toad would be adversely affected if the operation of the power plant reduces water quantity, 6 quality, or temperature at the springs in Dixie Valley. 7 BLM conducted an Environmental Assessment to analyze whether the Project would have 8 a significant effect on the environment, and specifically on the hot springs. BLM relied on a con- 9 ceptual hydrogeological model (ECF No. 24-3) supported by a 46-day flow test that replicated the 10 production volume and flow conditions analogous to operating the Phase I proposed 12 MW power 11 plant to determine that the deep geothermal reservoir is not directly connected to the springs and 12 that the springs will not be impacted by geothermal production. (Id. at 3-35 (test indicated “there

13 were no apparent influences of pumping and injection activities observed at [the springs]”); see 14 also EA, App. M (ECF No. 24-4).) BLM also assembled a technical working group comprised of 15 BLM hydrologists and biologists, along with representatives of the U.S. Fish and Wildlife Service 16 (“USFWS”), Nevada Department of Wildlife (“NDOW”), the Navy, and U.S. Geological Survey, 17 and in collaboration with Ormat, to develop the ARMMP for post-approval monitoring that would 18 supplement the pre-approval baseline monitoring and analysis conducted by Ormat. (Id. at 1-16; 19 ECF No. 13-26, ARMMP at 2.) The ARMMP is intended to serve as a backstop in the event that 20 uncertainties in the natural system result in unanticipated impacts to the springs. (See ECF No. 13- 21 26 at 4; see also ECF No. 13-23 at 5.) The ARMMP requires Ormat to continue and enhance its 22 1 In 2017, Plaintiff Center for Biological Diversity petitioned the U.S. Fish and Wildlife Service (“USFWS”) to list the toad as threatened or endangered. (ECF No. 13-25 at 3-77.) Though the 23 USFWS found that the petition presented sufficient information indicating that listing may be war- ranted, 83 Fed. Reg. 30,091, 30,091-93 (June 27, 2018), a final decision has yet to be made. (ECF 24 1 baseline monitoring, sets “early warning” thresholds (such as water levels, temperature, and chem- 2 ical composition), and, if those thresholds are reached, requires Ormat to implement mitigation 3 measures, including but not limited to, modifying or ceasing pumping and injection activities. (See 4 ECF No. 13-26 at 27–36.)2 5 In 2017, Ormat entered into a PPA that allows Ormat to sell power from projects coming 6 online before the end of 2022 at a fixed price of $75 per megawatt hour (“MWh”). (ECF No. 6-1 7 ¶ 17.) This rate is approximately $15 per MWh above current market rates. (Id. ¶¶ 17-18.) If the 8 Project does not begin delivering 12 MW of power by the end of December 2022, Ormat stands to 9 lose up to $30 million in revenue over 20 years. (ECF No. 24-1 ¶ 14.) Ormat provided a construc- 10 tion schedule for the Project beginning on January 6 and completing work in December 2022. (Id. 11 ¶ 4, Attachment 2.) Upon questioning at hearing, counsel for Ormat stated that Ormat would not 12 be able to complete construction within six months. (Tr. at 68:13-15.)

13 LEGAL STANDARD 14 An injunction is “an extraordinary remedy” awarded only “upon a clear showing that the 15 plaintiff is entitled to such relief.” Winter v. Nat. Res. Def. Council, Inc., 555 U.S. 7, 22 (2008). A 16 plaintiff bears the burden to “establish that he is likely to succeed on the merits, that he is likely to 17 suffer irreparable harm in the absence of preliminary relief, that the balance of equities tips in his 18 favor, and that an injunction is in the public interest.” Id. at 20. This test lays “out four conjunctive 19 tests, not a four-factor balancing test, using the word ‘likely’ to modify the success-on-the-merits 20

2 BLM also engaged in consultation with the State Historic Preservation Officer regarding the 21 visual and auditory effects from the presence of the power plants, as well as the potential effects to the springs and ethnobotanical plant communities in Dixie Meadows. (ECF No.

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Fallon Paiute-Shoshone Tribe v. U.S. Department of the Interior, Counsel Stack Legal Research, https://law.counselstack.com/opinion/fallon-paiute-shoshone-tribe-v-us-department-of-the-interior-nvd-2022.