## Facts

- The Boundary Waters Canoe Area Wilderness (BWCAW) is a large wilderness area within the Superior National Forest in Minnesota and is part of the National Wilderness Preservation System.
- Congress enacted the Wilderness Act (1964) and, for BWCAW specifically, the Boundary Waters Canoe Area Wilderness Act (1978), which includes detailed provisions governing motorboat and snowmobile use, portages, visitor quotas and permits, and certain commercial operations.
- In 1993, the U.S. Forest Service adopted the BWCA Wilderness Management Plan and Implementation Schedule (Wilderness Plan), establishing visitor-use restrictions and detailed motorboat quota and horsepower limits, among other management measures.
- Two sets of plaintiffs—(1) conservation organizations and outfitters and (2) counties and local user groups—filed separate suits challenging the Forest Service’s statutory interpretations and management choices embodied in the Wilderness Plan.
- Both cases sought judicial review under the Administrative Procedure Act (APA) and proceeded on cross-motions for summary judgment.
- The district court granted summary judgment to the federal defendants in both cases, upholding the Wilderness Plan.
- The appeals were consolidated in the Eighth Circuit.

## Issues

1. Whether the Wilderness Plan’s visitor-use restrictions and motorized-use controls were consistent with the BWCAW Act and the Wilderness Act, or instead were arbitrary, capricious, or contrary to law under the APA.
2. Whether the Forest Service lawfully implemented the BWCAW Act’s lake-specific motorboat and horsepower limits, including any allocations of quotas and use levels.
3. Whether the Forest Service lawfully implemented the BWCAW Act’s snowmobile and portage provisions without expanding or curtailing access beyond what Congress authorized.

## Decision

- The Eighth Circuit affirmed in part and reversed in part the district court’s grant of summary judgment for the federal defendants.
- The court upheld most of the Forest Service’s interpretations and management choices as reasonable implementations of the BWCAW Act within the broader framework of the Wilderness Act.
- The court reversed as to specific Plan components that conflicted with clear BWCAW Act directives or otherwise exceeded the agency’s statutory discretion.
- The case was remanded for further proceedings, requiring the Forest Service to revise the unlawful aspects while leaving the remainder of the Plan intact.

## Legal Principles

- Under the APA, courts set aside agency action that is arbitrary, capricious, an abuse of discretion, or contrary to law; statutory interpretations are assessed by first applying the statute’s clear text and, where ambiguity remains, accepting reasonable agency constructions.
- When a site-specific statute supplies detailed management rules for a particular unit, those specific directives control over more general statutory purposes or management principles.
- Courts defer to an agency’s technical and predictive judgments in visitor-use and resource-management planning when the governing statute leaves room for discretion and the agency provides a reasoned implementation.
- Agency discretion ends where Congress has fixed access levels, routes, or limits with clear, specific language; an agency may not effectively rewrite statutory baselines through planning measures that materially alter what the statute permits or forbids.

## Conclusion

The Eighth Circuit largely sustained the Forest Service’s BWCAW management plan under APA review, but required revisions where the plan departed from the BWCAW Act’s specific, mandatory limits on motorized use and related access provisions, reflecting enforcement of Congress’s detailed statutory compromise.


Friends of the Boundary Waters Wilderness v. Dombeck, 164 F.3d 1115 (8th Cir. 1999)