Oregon Natural Desert Ass'n v. Raby

ELR Citation: 55 ELR 20053
No(s). 3:25-cv-363-SI (D. Or. Apr 30, 2025) (Simon, J.)

A district court granted a conservation group's motion to preliminarily enjoin BLM from authorizing grazing in approximately 22,000 acres of land located in key research natural areas (RNAs) that were made unavailable to grazing in BLM's 2015 conservation plan for greater sage-grouse in Oregon. The group argued BLM's 2025 conservation plan, which reduced the number of ungrazed RNAs from 13 to 8 and cut the number of ungrazed areas within the RNAs by 83%, violated FLPMA and NEPA. The court found that opening the RNAs to grazing appeared to contravene the intended purpose of providing an ungrazed baseline against which to measure grazed lands, and that BLM failed to take a "hard look" at the consequences of reducing the number of RNAs below the minimum number it previously noted was necessary to support research. It granted the group's motion and enjoined BLM from authorizing grazing in any portions of the 13 RNAs.

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