ELR Citation: 53 ELR 20165
No(s). 2:23-cv-00435-CDS-DJA (D. Nev. Oct 18, 2023) (Silva, J.)

A district court denied environmental groups' motion to preliminarily enjoin implementation of a BLM-approved watershed restoration project in eastern Nevada. The groups argued BLM violated NEPA by failing to take a "hard look" at the project's impacts, and violated FLPMA by failing to address special status species requirements in the relevant resource management plan (RMP). The court found the EA included analyses of site-specific impacts as well as habitat- and species-specific impacts, and that it sufficiently analyzed cumulative impacts of grazing. It further found BLM considered the habitat needs of bat species as required by the RMP and did not violate the proscribed fire requirements in sage grouse habitats; but that the agency failed to address the requirement to replace lost special status species habitat. The court ultimately determined that the groups failed to show they were likely to suffer irreparable harm absent preliminary relief, and denied the motion.