Defenders of Wildlife v. Salazar
ELR Citation: ELR 20102 No(s). 08-0945 (D.D.C. Mar 26, 2010)
A district court denied environmental groups’ motion for summary judgment and granted the U.S. Fish and Wildlife Service's and the National Park Service’s cross motion for summary judgment relating to claims that the agencies’ comprehensive Bison and Elk Management Plan violates the National Wildlife Refuge System Improvement Act and NEPA. The plan does not violate the Improvement Act by permitting indefinite supplemental feeding of elk because it is reasonable in light of the provisions and purposes of the Act and the agencies have articulated a satisfactory explanation for the balance they have struck given the factual record. The plan and its EIS do not violate NEPA because they incorporate enough mitigation measures to provide a reasonably complete discussion of mitigation.