Western Watersheds Project v. Grimm

ELR Citation: 48 ELR 20004
No(s). 1:16-cv-00218 (D. Idaho Jan 4, 2018) (Lodge, J.)

A district court held that USDA Wildlife Services did not violate NEPA with its lethal wolf management policy in Idaho. In 2011, the gray wolf was delisted under the ESA in Idaho; as a result, management of the wolf population was returned to the state. Wildlife Services conducted an EA in 2011 concerning its involvement in the Idaho wolf management program. The agency issued a FONSI and agreed to adhere to Standard Operating Procedures detailed in the 2011 EA and annual monitoring to ensure that environmental impacts would remain as described in the 2011 EA. Concerned environmental groups claimed that the agency violated NEPA by not engaging in a "hard look," and that an EIS was required. The Service claimed that it properly examined the environmental impact of its involvement and that the groups lacked standing. The court agreed that the groups lacked standing, as challenging the FONSI would not redress their issue since the gray wolf is no longer listed under the ESA and therefore, not under Wildlife Services' control. The case was dismissed. 

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