ELR Citation: 56 ELR 20022
No(s). 26-317 (RDM) (D.D.C. Mar 1, 2026) (Moss, J.)

A district court granted environmental groups' motion for a preliminary injunction in a challenge to BLM's decision to grant the Utah Department of Transportation (UDOT) a right-of-way (ROW) to construct a highway across Red Cliffs National Conservation Area. The groups argued BLM's approval of the ROW violated the Omnibus Public Land Management Act (OPLMA), that BLM failed to adequately explain the basis for its decision to reverse its prior conclusion that the project was incompatible with the OPLMA, and that the 2025 biological opinion's conclusion that the highway was not likely to jeopardize the Mojave desert tortoise or destroy its critical habitat was arbitrary and capricious. The court concluded the 2026 record of decision either misconstrued the OPLMA or failed to offer a reasoned explanation for its departure from the agency's 2024 standard and approval of the ROW application. It granted the motion and enjoined further activity associated with the ROW.