ELR Citation: 54 ELR 20047
No(s). 22-cv-1853 (CRC) (D.D.C. Mar 22, 2024) (Cooper, J.)

A district court denied summary judgment for conservation groups in a challenge to BLM's authorization of six lease sales for oil and gas development in the western United States. The groups argued BLM failed to take the requisite "hard look" when analyzing the cumulative impact of greenhouse gas emissions, wrongly adopted a piecemeal approach by reviewing the six sales in isolation rather than in unison, erred in issuing a FONSI and refusing to prepare an EIS, and violated its duty under FLPMA to avoid “unnecessary or undue degradation” of the affected lands. The court found BLM reasonably exhausted available tools to analyze environmental consequences, and that there was no reason to conclude the sales would cause "unnecessary and undue degradation" under FLPMA. It denied summary judgment for the groups and granted BLM's cross-motion.