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

CourtDistrict Court, D. Nevada
DecidedMarch 31, 2025
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. 2025).

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 Summary Judgment and Granting 6 v. Defendants’ Motion for Summary Judgment

7 U.S. Department of the Interior, et al., [ECF Nos. 25, 26] 8 Defendants

9 10 Plaintiffs Western Watersheds Project and the Center for Biological Diversity bring this 11 action against defendants U.S. Department of the Interior, Bureau of Land Management, Jared 12 Bybee in his official capacity as Field Manager of the Bureau of Land Management Bristlecone 13 field office, and Shirley Johnson in her official capacity as Field Manager of the Bureau of Land 14 Management Caliente field office, to stop the implementation of the South Spring Valley and 15 Hamlin Valley Watersheds Restoration Project (hereinafter referred to collectively as “the 16 Project”). Compl., ECF No. 1. Plaintiffs argue that the Project’s environmental assessment 17 violates the Administrative Procedure Act (APA), National Environmental Policy Act (NEPA), 18 and the Federal Land Policy and Management Act (FLPMA). Id. at 40, 41. On March 22, 2024, 19 plaintiffs filed a motion for summary judgment. Pls.’ mot. for summ. j., ECF No. 25. Defendants 20 filed a response to the motion for summary judgment, which was also its own cross-motion for 21 summary judgment. Defs.’ mot. for summ. j., ECF No. 26.1 I held oral argument on the motions on 22 February 19, 2025. ECF No. 33. For the reasons herein, I grant defendants’ motion for summary 23 judgment and deny plaintiffs’ motion for summary judgment. 24

25 26 1 At the hearing I cautioned defendants that the combined response and countermotion violates Local Rule IC 2-2(b). Defendants were advised that future violations of the local rules may result in sanctions. 1 I. Background 2 On October 18, 2023, I denied plaintiffs’ motion for preliminary injunction and motion 3 for temporary restraining order. Order, ECF No. 19. I incorporate by reference, as if set forth fully 4 herein, the facts presented in that order. 5 II. Legal standard 6 Summary judgment is appropriate when the pleadings and admissible evidence “show 7 that there is no genuine issue as to any material fact and that the movant is entitled to judgment 8 as a matter of law.” Celotex Corp. v. Catrett, 477 U.S. 317, 322 (1986) (citing Fed. R. Civ. P. 56(c)). 9 At the summary-judgment stage, the court views all facts and draws all inferences in the light 10 most favorable to the nonmoving party. Kaiser Cement Corp. v. Fishbach & Moore, Inc., 793 F.2d 1100, 11 1103 (9th Cir. 1986). If reasonable minds could differ on material facts, summary judgment is 12 inappropriate because its purpose is to avoid unnecessary trials when the facts are undisputed; 13 the case must then proceed to the trier of fact. Warren v. City of Carlsbad, 58 F.3d 439, 441 (9th Cir. 14 1995); see also Nw. Motorcycle Ass’n v. U.S. Dep’t of Agric., 18 F.3d 1468, 1471 (9th Cir. 1994). 15 Once the moving party satisfies Rule 56 by demonstrating the absence of any genuine 16 issue of material fact, the burden shifts to the party resisting summary judgment to “set forth 17 specific facts showing that there is a genuine issue for trial.” Anderson v. Liberty Lobby, Inc., 477 U.S. 18 242, 256 (1986); Celotex, 477 U.S. at 323. “To defeat summary judgment, the nonmoving party 19 must produce evidence of a genuine dispute of material fact that could satisfy its burden at trial.” 20 Sonner v. Schwabe N. Am., Inc., 911 F.3d 989, 992 (9th Cir. 2018). “When simultaneous cross-motions 21 for summary judgment on the same claim are before the court, the court must consider the 22 appropriate evidentiary material identified and submitted in support of”—and against—“both 23 motions before ruling on each of them.” Tulalip Tribes of Wash. v. Washington, 783 F.3d 1151, 1156 (9th 24 Cir. 2015) (citing Fair Hous. Council of Riverside Cnty., Inc. v. Riverside Two, 249 F.3d 1132, 1134 (9th 25 Cir. 2001)). 26 1 III. Discussion 2 A. Plaintiffs’ motion for summary judgment is denied and defendants’ motion for summary judgment is granted. 3 4 Defendants’ motion for summary judgment also operates as its response to plaintiffs’ 5 motion for summary judgment. ECF No. 26. Therefore, I address both motions simultaneously. 6 In their motion, plaintiffs argue that the Project violates both the FLPMA and NEPA. I address 7 each statute in turn. 8 9 When Congress enacted the FLPMA it declared that “it is the policy of the United States 10 to manage the public lands ‘in a manner that will protect the quality of scientific, scenic, 11 historical, ecological, environmental, air and atmospheric, water resource and archeological 12 values.’” Ctr. for Biological Diversity v. U.S. Dep’t of Interior, 581 F.3d 1063, 1075 (9th Cir. 2009) 13 (quoting 43 U.S.C. § 1701(a)(8)). To effectuate this, FLPMA requires the BLM to produce land 14 use plans known as Resource Management Plans (RMPs). Norton v. S. Utah Wilderness All., 542 15 U.S. 55, 59 (2004) (citing 43 C.F.R. § 1601-5(k) (2003)). “While RMPs are ‘designed to guide 16 and control future management actions’ BLM has ‘a great deal of discretion in deciding how to 17 achieve compliance with an RMP.” W. Watersheds Project v. United States DOI, 2023 U.S. Dist. LEXIS 18 186760, at *24 (D. Nev. Oct. 18, 2023) (citing Ctr. for Biological Diversity v. United States BLM, 2017 19 U.S. Dist. LEXIS 137089, at *44 (D. Nev. Aug. 23, 2017)). Despite this discretion, BLM may not 20 “take actions ‘inconsistent with the provisions of a land use plan.’” Ctr. for Biological Diversity, 2017 21 U.S. Dist. LEXIS 137089, at *43–44 (quoting Norton, 542 U.S. at 69). The RMP at issue here is 22 the 2008 ELY RMP, AR_03776–04254, as amended by the 2015 Approved Resource 23 Management Plan Amendments (ARMPAs), AR_08634–08737. Plaintiffs argue that the Project 24 violates FLPMA because it violates the land use plan by failing to comply with the ELY RMP’s 25 three special-status species requirements. ECF No. 25 at 18–27. 26 1 2 3 The ELY RMP requires BLM to “mitigate all discretionary permitted activities that result 4 in the loss of special status species habitats on a ratio of two acres of comparable habitat for 5 every one acre of lost habitat as determined on a project-by-project basis.” AR_03839. At issue is 6 the meaning of the term “permitted activities.” Plaintiffs argue that BLM has violated FLPMA 7 because it failed to comply with this 2:1 mitigation requirement. BLM concedes that it does not 8 apply the 2:1 mitigation requirement but claims that this project is exempt from the 2:1 9 mitigation requirement because “permitted activities” as used in the ELY RM applies only 10 “when a party must apply to the BLM for a permit to use the land.” ECF No. 25 at 18. Plaintiffs 11 argue that this is incorrect because the term “permitted activities” does not mean “with a 12 permit” but instead unambiguously means “with permission.” Id. at 19.

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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-2025.