ELR Citation: 51 ELR 20090
No(s). 19-35528 (9th Cir. May 18, 2021)

In an unpublished opinion, the Ninth Circuit affirmed summary judgment for the Forest Service in a lawsuit concerning domestic sheep grazing in the Beaverhead-Deerlodge National Forest. Environmental groups argued the Service violated the National Forest Management Act, NEPA, and the APA by utilizing a flawed coarse filter methodology to determine that the grazing did not pose a significant threat to the viability of bighorn sheep in the national forest. The court found that in conducting the analysis, the Service considered threats from domestic sheep grazing to bighorn sheep, discussed impacts on bighorn sheep viability, and adequately delineated reasons why it used the coarse filter methodology rather than a fine filter analysis. It therefore affirmed summary judgment for the Forest Service.