Western Watersheds Project v. U.S. Department of the Interior

CourtDistrict Court, D. Nevada
DecidedOctober 18, 2023
Docket2:23-cv-00435
StatusUnknown

This text of Western Watersheds Project v. U.S. Department of the Interior (Western Watersheds Project 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
Western Watersheds Project v. U.S. Department of the Interior, (D. Nev. 2023).

Opinion

1 2 UNITED STATES DISTRICT COURT DISTRICT OF NEVADA 3 4 Western Watersheds Project, et al., Case No. 2:23-cv-00435-CDS-DJA

5 Plaintiffs Order Denying Plaintiffs’ Motion for Preliminary Injunction and Plaintiffs’ 6 v. Motion for Temporary Restraining Order

7 U.S. Department of the Interior, et al., [ECF Nos. 14, 17]

8 Defendants 9 10 Plaintiffs Western Watersheds Project and the Center for Biological Diversity (together, 11 plaintiffs) seek a preliminary injunction to halt the implementation of the South Spring Valley 12 and Hamlin Valley Watersheds Restoration Project (hereinafter, the Project), arguing that the 13 Project’s environmental assessment violates the Administrative Procedure Act (APA), National 14 Environmental Policy Act (NEPA), and the Federal Land Policy and Management Act (FLPMA). 15 ECF No. 14. Defendants filed their opposition (ECF No. 15), to which plaintiffs replied (ECF No. 16 16). This motion is now fully briefed. Plaintiffs subsequently filed a motion for temporary 17 restraining order. ECF No. 17. For the reasons set forth herein, plaintiffs’ motion for preliminary 18 injunction and motion for temporary restraining order are DENIED.1 19 I. Procedural History 20 On March 23, 2023, plaintiffs filed a complaint for declaratory and injunctive relief 21 against the U.S. Department of the Interior, the U.S. Bureau of Land Management (BLM), Jared 22 Bybee, as Field Manager of the BLM Bristlecone Field Office, and Kenneth Kendrick,2 as Acting 23 Field Manager of the BLM Caliente Field Office. Compl., ECF No. 1. The complaint challenges 24

25 1 The court is not ruling on the merits of plaintiffs’ claims. This order only addresses plaintiffs’ motion for preliminary injunction (ECF No. 14) and temporary restraining order (ECF No. 17). 26 2 Under Fed. R. Civ. P. 25(d), Kenneth Kendrick is automatically substituted for former Field Managers Shirley Johnson and Alicia Styles as a defendant. 1 the South Spring Valley and Hamlin Valley Watershed Restoration Plan Decision Record 2 (Decision Record),3 the associated final environmental assessment (EA), and finding of no 3 significant impact (FONSI). Id. 4 On August 23, 2023, plaintiffs filed the instant motion for a preliminary injunction to 5 stop defendants from implementing part of the Project,4 asserting: (1) the Project EA violated 6 NEPA, and (2) that the Project violated FLPMA by failing to ensure it complied with the Ely 7 Resource Management Plan (Ely RMP).5 See ECF No. 14. Defendants oppose the motion, 8 arguing: (1) plaintiffs fail to demonstrate that an injunction is warranted, (2) plaintiffs 9 mischaracterize the purpose behind the Project, and (3) despite plaintiffs’ disagreement with 10 the implementation strategy, the Project is both “legal” and “well-considered.” See generally ECF 11 No. 15. On October 11, 2023, plaintiffs filed the instant motion for a temporary restraining order 12 to prevent imminent irreparable harm and to preserve the status quo pending this court’s 13 decision on their motion for preliminary injunction. ECF No. 17 at 1. I rule on both motions in 14 this one order because the standard for issuing a preliminary injunction is “essentially identical” 15 to the standard for issuing a temporary restraining order. Chandler v. Williams, 2010 WL 3394675, 16 at *1 (D. Or. Aug. 26, 2010) (citing Stuhlbarg Int’l Sales Co., Inc. v. John D. Brush & Co., 240 F.3d 832, 17 839 n.7 (9th Cir. 2001)). 18 19 20 3 The Decision Record discusses the factors considered in approving the Project. The Decision Record is 21 included as plaintiffs’ Exhibit 18 to their motion for preliminary injunction and is discussed further infra section II. 22 4 The Project Area is located within northeast Lincoln County, Nevada and southeast White Pine 23 County, Nevada. EA, Defs.’ Ex. 5, ECF No. 15-5 at 7. The Project at issue in this case involves approximately 2,000 acres of the Project Area. Email Exchange re Protect timeline, Pls.’ Ex. 19, ECF No. 24 14-19 at 5. The overall Project Area is approximately 666,531 acres. EA, Defs.’ Ex. 5, ECF No. 15-5 at 7.

25 5 The Federal Land Policy Management Act (FLPMA) directs the BLM to develop and maintain comprehensive Resource Management Plans (RMPs), such as the Ely RMP, that governs all aspects of 26 public land management. See 43 U.S.C. § 1712. The Ely RMP, which was produced in November of 2008, is included as defendants’ Exhibit 3, ECF No. 15-3, and is further discussed infra in Section B. 1 II. Background 2 In 2008, the BLM evaluated the South Spring Valley and Hamlin Valley watersheds to 3 determine if they met BLM’s rangeland health standards. EA, Defs.’ Ex. 5, ECF No. 15-5 at 5. The 4 BLM uses these standards to determine whether watersheds are functioning properly; whether 5 water quality complies with state water quality requirements; whether habitats of protected 6 species are functioning properly; and whether ecological processes are functioning properly to 7 support healthy biotic populations and communicates. Ely District Record of Decision and 8 Approved Resource Management Plan, Pls.’ Ex. No 13, ECF No. 14-13 at 8. The evaluation 9 indicated that the vegetation communities and riparian areas that exist within the watersheds 10 did not meet the desired range of conditions for each community as specified in the Ely RMP. 11 EA, Defs.’ Ex. 5, ECF No. 15-5 at 5, 7. Both watersheds had a problematic increase of wood 12 species, including pinyon-juniper, which decrease grasses and forbs6 in the understory 13 vegetation. Id. at 6. The evaluation also showed that both valleys were at a moderate to high risk 14 of wildfire. Id. 15 To improve watershed health in the South Spring and Hamlin Valley Watersheds, as 16 well as to meet the Ely RMP objectives, the BLM analyzed the environmental impact of treating 17 the vegetation of both watersheds under three alternatives. Id. at 7, 10. After 2008, the BLM 18 worked with state wildlife agencies and commissioned additional resources to identify the 19 needs and impact of implementing this project. See Record of Decision and Approved Resource 20 Management Plan Amendments for the Great Basin Region (ARMPA) ECF No. 15-4 at 4–5. This 21 included Nevada-specific considerations, which incorporated information from state 22 conservation plans and research. See id. at 42–43; see also 2020 Fuels Reduction and Rangeland 23 Restoration in the Great Basin Environmental Impact Statement (FRRR FEIS), Defs.’ Ex. 1, ECF 24 25

26 6 A forb is defined as an herb other than grass. See https://www.merriam-webster.com/dictionary/forb (last accessed October 13, 2023). 1 No. 15-1. The BLM’s efforts resulted in the creation of the FRRR FEIS and ultimately, the EA. 2 EA, Defs.’ Ex. 5, ECF No. 15-5. 3 On June 23, 2021, a preliminary EA for the Project’s proposal was released, and public 4 comments were accepted for a period of thirty days. FONSI, Defs.’ Ex. 8, ECF No. 15-8 at 2. On 5 September 28, 2022, the BLM released their Decision Record which approved the Project and 6 issued a FONSI. Id.; see also Decision Record, Pls.’ Ex. 18, ECF No. 14-18 at 2. The BLM 7 determined that the Project “will not significantly affect the quality of the human environment 8 and that an Environmental Impact Statement is not required.” FONSI, Defs.’ Ex. 8, ECF No. 15-8 9 at 2–3.

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Western Watersheds Project v. U.S. Department of the Interior, Counsel Stack Legal Research, https://law.counselstack.com/opinion/western-watersheds-project-v-us-department-of-the-interior-nvd-2023.