ELR Citation: 56 ELR 20051
No(s). 24-518 (TJK) (D.D.C. Mar 30, 2026) (Kelly, J.)

A district court denied environmental groups' motion for summary judgment in a challenge to timber targets set by the Forest Service and certain timber projects. The groups argued the Service violated NEPA by setting the targets without conducting environmental review, and that the projects violated NEPA because their EAs failed to properly weigh cumulative carbon emissions. The court found that setting the targets did not constitute final agency action, as it was a complex, years-long process rather than a discrete agency action; and that, given the substantial judicial deference owed under Seven County Infrastructure Coalition v. Eagle County, the Service adequately considered the cumulative carbon-emitting effects of the projects. It denied summary judgment for the groups and granted the Service's cross-motion.