Northwest Environmental Advocates v. United State National Marine Fisheries Service (NMFS)

CourtDistrict Court, D. Oregon
DecidedFebruary 11, 2025
Docket3:21-cv-01591
StatusUnknown

This text of Northwest Environmental Advocates v. United State National Marine Fisheries Service (NMFS) (Northwest Environmental Advocates v. United State National Marine Fisheries Service (NMFS)) is published on Counsel Stack Legal Research, covering District Court, D. Oregon primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Northwest Environmental Advocates v. United State National Marine Fisheries Service (NMFS), (D. Or. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF OREGON

NORTHWEST ENVIRONMENTAL ADVOCATES, a non-profit organization, Case No. 3:21-cv-01591-AB Plaintiff, OPINION AND ORDER v.

UNITED STATES NATIONAL MARINE FISHIERIES SERVICE, a United States Government Agency; JENNIFER QUAN, in her official capacity as NMFS Regional Administrator for the West Coast Region; THE UNITED STATES ENVIRONMENTAL PROTECTION AGENCY, a United States Government Agency; and MICHAEL REGAN, in his official capacity as EPA Administrator,

Defendants.

Allison LaPlante Attorney at Law 333 NE Russell St., #200 Portland, OR 97212

Lydia Dexter Earthrise Law Center Lewis & Clark Law School 10101 S Terwilliger Blvd. Portland, OR 97219 Bryan Telegin Telegin Law 175 Parfitt Ave., SW Suite N270 Bainbridge Island, WA 98110

Attorneys for Plaintiff

Toddy Kim J. Brett Grosko Environment & Natural Resources Section U.S. Department of Justice P.O. Box. 7369 Washington, D.C. 20044

Attorneys for Defendants

BAGGIO, District Judge:

Plaintiff Northwest Environmental Advocates (“NWEA”) brings this case under the Administrative Procedure Act (“APA”), 5 U.S.C. § 706(2)(A), and the Endangered Species Act (“ESA”), 16 U.S.C. § 1536(a)(2), against Defendants United States National Marine Fisheries Service (“NMFS”); Jennifer Quan, in her official capacity as the NMFS Regional administrator for the West Coast Region; the United States Environmental Protection Agency (“EPA”); and Michael Regan, in his official capacity as the EPA Administrator.1 Plaintiff challenges Defendant NMFS’s November 2015 Biological Opinion (“BiOp”) and Defendant EPA’s reliance on that BiOp to comply with the ESA in its approval of Oregon’s water quality criteria for temperature. Plaintiff now moves to supplement the administrative record and take discovery. For the reasons that follow, the Court grants in part and denies in part Plaintiff’s motion. /// ///

1 The Court refers to Defendants NMFS and Jennifer Quan as “Defendant NMFS” and Defendants EPA and Michael Regan as “Defendant EPA.” BACKGROUND This case is the fourth in a series of cases involving Oregon’s rivers and the survival of its cold water fish. Many salmonid species in the Pacific Northwest are listed as threatened or endangered, in part because of human-caused river temperature increases. Second Am. Compl. (“SAC”) ¶¶ 47–48, ECF No. 45. High temperatures can cause increased mortality among

juvenile salmonids, increased susceptibility to diseases, and altered migration timing. SAC ¶ 50. In 2015, for example, excessively warm water in the Columbia and Snake Rivers killed 250,000 adult sockeye salmon when they were prevented from successfully migrating upstream. SAC ¶ 51. I. Litigation History In the early 1990s, Oregon began developing new standards for river temperatures as part of its Clean Water Act Triennial Review, 33 U.S.C. § 1313(c)(1). SAC ¶ 52. The 1996 standards set a 20°C criterion for salmonid rearing and migration in the Lower Willamette River and a 17.8°C criterion for salmon rearing without any information as to where and when this lower

criterion applied. SAC ¶¶ 52, 55. Three years later, NMFS completed a biological opinion that the 20°C standard was likely to adversely affect salmonids but would not jeopardize the species based on certain promises made by Oregon. SAC ¶ 53. Ultimately, the EPA did not approve the 20°C criterion but no further action was taken by Oregon or the EPA on this standard. SAC ¶ 53. While NMFS and the EPA expressed concerns about the lack of detail related to the 17.8°C criterion, the EPA ultimately approved this lower standard. SAC ¶ 55. In 2011, NWEA sued the EPA for failing to act and promulgate replacement temperate criteria for salmonid rearing and migration in the Lower Willamette River after it did not approve the 20°C standard. See Nw. Env’t Advocs. v. U.S. Env’t Prot. Agency (“NWEA I”), No. CV-01-510-HA (D. Or.). The district court concluded that the EPA was under a nondiscretionary duty to act and had failed to do so under the Clean Water Act. NWEA I, 268 F. Supp. 2d 1255, 1261 (D. Or. 2003). The court also concluded that the EPA’s approval of the 17.8°C temperature criterion and the NMFS biological opinion were arbitrary and capricious in light of the lack of detail surrounding the application of this criterion. Id. at 1267–68, 1273. The EPA was ordered

to rescind portions of its 1999 approval of Oregon’s temperature standards and approve new Oregon standards by March 2, 2004. SAC ¶ 56. While litigation was ongoing in NWEA I, the EPA promulgated regional temperature guidance that recommended both numeric temperature criteria and narrative provisions to protect salmonids. SAC ¶ 57. It recommended states include “a provision to protect and, where feasible, restore the natural thermal regime” and recognized that rivers with significant hydrologic alterations may lose significant temperature diversity such that “maximum temperatures occur for an extended period of time and there is little cold water refugia available for fish to escape maximum temperatures.” SAC ¶ 57 (citing Regional Temperature Guidance at 25); see also SAC

¶ 58 (“Although some altered rivers . . . experience similar summer maximum temperatures today as they did historically, there is a big difference between the temperatures that fish experience today versus what they likely experienced historically” because of their “high degree of spatial and temporal temperature diversity . . . .”). After NWEA I, Oregon revised its water quality standards for temperature to include both numeric and narrative criteria. SAC ¶ 59. These standards, however, also included a “natural conditions criterion,” allowing Oregon to change the numeric temperature criteria upwards without any federal agency review if it determined that water temperatures were “naturally” hotter. SAC ¶ 59. In 2003, Oregon submitted these standards to EPA for approval. SAC ¶ 59. After NMFS found Oregon’s revised water quality standards did not jeopardize the ESA-listed salmonid species, the EPA approved the 2003 standards. SAC ¶ 59. NWEA challenged the EPA’s approval of Oregon’s 2003 temperature standards and the related biological opinions. See Nw. Env’t Advocs. v. U.S. Env’t. Prot. Agency (“NWEA II”), No. 3:05:cv-01876-AC (D. Or.). In 2013, the court held that the natural conditions criterion was

unlawful. NWEA II, 855 F. Supp. 2d 1199, 1217 (D. Or. 2012). But the court upheld the EPA’s approval of the 20°C numeric criterion while expressing some concerns “regarding the uncertainty inherent in the approval of the 20°C criterion and the attendant narrative provision calling for sufficient coldwater refugia . . . .” Id. at 1214. As to the relevant biological opinions, the court concluded NMFS’s review was arbitrary and criticized NMFS for adopting the 20°C criterion as an improvement over current water temperatures rather than looking to the biological needs of existing salmonids. Id. at 1222–1231. The court ordered the EPA to disapprove the natural conditions criterion and for NMFS to reconsider its biological opinion. SAC ¶¶ 62, 64. While NWEA II was still ongoing, NWEA challenged the EPA’s approval of Oregon’s 2004-2010 temperature Total Maximum Daily Load (“TMDL”)2 clean-up plans. Nw. Env’t

Advocs. v. U.S. Env’t Prot.

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Northwest Environmental Advocates v. United State National Marine Fisheries Service (NMFS), Counsel Stack Legal Research, https://law.counselstack.com/opinion/northwest-environmental-advocates-v-united-state-national-marine-fisheries-ord-2025.