ELR Citation: 53 ELR 20125
No(s). 22-8022 (10th Cir. Aug 7, 2023)

The Tenth Circuit affirmed a district court ruling upholding BLM's approval of a development project on state and federal land in southwestern Wyoming. Conservation groups argued BLM violated NEPA by failing to adequately consider impacts of the project on sage-grouse populations and pronghorn antelope migration and grazing patterns, and violated FLPMA by failing to require development to be phased across the project area as required by the land use plan. The court concluded BLM adequately collected and considered information on the sage-grouse and pronghorn, and selected a development plan that meets statutory requirements. It affirmed the district court ruling.