Native Ecosystems Council v. Judice

CourtDistrict Court, D. Montana
DecidedApril 29, 2020
Docket1:18-cv-00157
StatusUnknown

This text of Native Ecosystems Council v. Judice (Native Ecosystems Council v. Judice) is published on Counsel Stack Legal Research, covering District Court, D. Montana primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Native Ecosystems Council v. Judice, (D. Mont. 2020).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MONTANA BILLINGS DIVISION NATIVE ECOSYSTEMS COUNCIL, CV 18-157-BLG-SPW Plaintiff, ORDER VS. JOHN J. MEHLHOFF, State Director,! the BUREAU OF LAND MANAGEMENT, DEPARTMENT OF THE INTERIOR; et al., Defendants.

Before the Court are Magistrate Judge Cavan’s Findings and

Recommendations, (Doc. 39), regarding the parties’ cross-motions for summary judgment. Native Ecosystems Council (“NEC”) has filed objections, (Doc. 40), and

the Bureau of Land Management (“BLM”) has filed a response, (Doc. 42). For the

following reasons, the Court adopts Judge Cavan’s Findings and Recommendations in part.

| Substituted by operation of Rule 25(d) of the Federal Rules of Civil Procedure for the former Acting State Director, Donato Judice.

I. Background The parties do not object to Judge Cavan’s findings with respect to the

background of this case, (Doc. 39 at 1—5), and the Court adopts them in full. After assessing four watersheds in southwestern Montana as part of its 2006 Resource Management Plan, BLM determined that, without intervention, conifer encroachment would convert each watershed’s sagebrush steppe habitat into forest habitat. (id. BLM prepared Environmental Assessments for each watershed and proposed mitigating the conifer expansion through a combination of prescribed fire and mechanical treatments. (/d.) Following a comment period, BLM issued a

Notice of Final Decision along with a Finding of No Significant Impact for each

watershed, approving the prescribed fire and mechanical treatments. (Jd. at 2-3.) While this process was ongoing, however, BLM amended its Resource

Management Plan to address the “present or threatened destruction” of sage grouse habitat and range (the “Sage Grouse Amendment”). (/d. at 3; Doc. 13-20

[hereinafter SGRMP] at 11.) The BLM issued the Sage Grouse Amendment in

response to the United States Fish and Wildlife Service’s finding that the greater

sage grouse was “warranted, but precluded,” for listing as a threatened or endangered species. (SGRMP at 11.) Among other changes, the Sage Grouse Amendment

required BLM to consider additional criteria before using prescribed burns in greater

sage grouse habitat. (SGRMP at 48.) NEC brought this action to prevent BLM from completing the prescribed burns in the four watersheds. NEC argues that the watershed projects ignore the Sage Grouse Amendment’s requirements for prescribed burns and BLM’s authorization of the prescribed burns was arbitrary and capricious, an abuse of discretion, and otherwise not in accordance with the law. (Doc. 39 at 4); see (Doc. 1 at § 2; Doc. 18 at 12-13, 16-20). The parties filed cross-motions for summary judgment. (Doc. 16; Doc. 28.) Judge Cavan disagreed with NEC and recommended the Court grant summary judgment in BLM’s favor with respect to three of the four watersheds. Regarding the fourth, the Centennial Watershed, Judge Cavan recommended denying both cross-motions to allow for additional briefing. (Doc. 39 at 45-46.) II. Legal Standard When a party timely objects to any portion of the Findings and Recommendations, the Court must review those portions of the Findings and Recommendations de novo. 28 U.S.C. § 636(b)(1); McDonnell Douglas Corp. v.

Commodore Business Machines, 656 F.2d 1309, 1313 (9th Cir. 1981). “A judge of

the court may accept, reject, or modify, in whole or in part, the findings or recommendations made by the magistrate judge. The judge may also receive

further evidence or recommit the matter to the magistrate judge with instructions.” 28 U.S.C. § 636(b)(1). The Court needs not review the factual and legal conclusions to which the parties do not object. United States v. Reyna-Tapia, 328 F.3d 1114, 1121 (9th Cir. 2003). NEC first objects to the standard of review Judge Cavan applied in his Findings and Recommendations. NEC argues that while the Findings and Recommendations analyze BLM’s watershed projects under the National Environmental Policy Act (“NEPA”), the thrust of its argument actually concerns violations of the Federal Land Policy and Management Act (“FLPMA”). (Doc. 40

at 2.) Courts review NEPA under the Administrative Procedure Act (“APA”) by determining whether an agency action is “arbitrary, capricious, an abuse of discretion, or otherwise not in accordance with the law.” 5 U.S.C. § 706(2)(A); see (Doc. 39 at 5-8 (discussing the highly deferential standard for NEPA decisions under the APA)). Judicial review under the APA of a NEPA action is narrow and limited to whether the agency “took a ‘hard look’ at the environmental impacts of a proposed action.” Nat’! Parks & Conservation Ass'n v. Bureau of Land Mgmt., 606 F.3d 1058, 1072 (9th Cir. 2010). On the other hand, courts review BLM’s actions under FLPMA to determine whether they are consistent with applicable Resource

Management Plans. 43 U.S.C. § 1732(a); Norton v. Southern Utah Wilderness Alliance, 542 U.S. 55, 69 (2004). FLPMA’s standard is therefore less deferential. Actions that the Court determines are inconsistent with a Resource Management Plan are “not in accordance with the law,” 5 U.S.C. § 706(2)(A), even if the Court finds the agency otherwise took a hard look at the environmental impacts of the proposed actions under NEPA. BLM argues that NEC raised its arguments under FLPMA for the first time in

its objections. However, the Court finds that while NEC rarely referred back to and analyzed FLPMA in its original briefing, it did successfully raise arguments under

FLPMA each time it argued one of BLM’s proposed watershed projects was

inconsistent with BLM’s Resource Management Plan (both before and after the Sage Grouse Amendment). See (Doc. 16 at 23-31.) Nevertheless, while the Findings and Recommendations do “sound almost

exclusively in NEPA,” (Doc. 40 at 2), this is because Management Decision Fire 3 1?

* Management Decision Fire 31 states the following: If prescribed fire is used in GRSG habitat, the NEPA analysis for the Burn Plan will address: e why alternative techniques were not selected as viable options; e how GRSG goals and objectives will be met by its use; e how the COT Report objectives will be addressed and met; e arisk assessment to address how potential threats to GRSG habitat will be minimized. Allow prescribed fire as a vegetation or fuels treatment in Wyoming big sagebrush sites or other xeric sagebrush species sites, or in areas with a potential

—NEC’s primary point of contention between the Resource Management Plan, the Sage Grouse Amendment, and the proposed watershed projects—adds new requirements for a NEPA analysis whenever “prescribed fire is used in a [greater sage grouse] habitat.” (SGRMP at 48.) Therefore, NEC’s FLPMA and NEPA claims substantially overlap.

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Native Ecosystems Council v. Judice, Counsel Stack Legal Research, https://law.counselstack.com/opinion/native-ecosystems-council-v-judice-mtd-2020.