## Facts

- Environmental organizations challenged federal actions facilitating coal development on federally owned or controlled lands in the Northern Great Plains (parts of Wyoming, Montana, North Dakota, and South Dakota).
- Federal agencies, primarily within the Department of the Interior, issued coal leases, approved mining plans, and took related actions enabling private development of coal reserves.
- Plaintiffs sought declaratory and injunctive relief requiring the government to prepare a single, comprehensive environmental impact statement (EIS) for the entire region before any further coal development could proceed.
- Agencies were also participating in the Northern Great Plains Resources Program, a multi-state study assessing potential environmental impacts of resource development.
- The district court granted summary judgment for the government, holding the complaint failed to state a NEPA claim because there was no proposal for legislation or major federal action for the region as a whole.
- The D.C. Circuit reversed, reasoning that contemplated regional planning, including the study process, could trigger NEPA at a regional scale; it remanded with instructions tied to future agency “control” of development and enjoined certain mining plan approvals despite an existing site-specific EIS.

## Issues

1. Whether NEPA § 102(2)(C) requires a single, comprehensive EIS for an entire multi-state region absent a concrete, proposed regional development plan or program.
2. Whether multiple local projects and general planning studies constitute a “proposal for major Federal action” at the regional level sufficient to trigger a regional EIS.

## Decision

- The Supreme Court reversed the D.C. Circuit.
- The Court held that NEPA did not require an EIS covering the entire Northern Great Plains on the record presented.
- The Court rejected treating contemplated regional planning and ongoing studies as the equivalent of a regional “proposal for major Federal action.”
- The Court concluded that, without a defined regional proposal, a regional EIS would be impractical and speculative.
- The Court’s disposition nullified the court of appeals’ remand instructions and related injunction premised on a mandatory regional EIS.

## Legal Principles

- NEPA’s EIS duty under § 102(2)(C) is triggered by a concrete “proposal for legislation” or “major Federal action,” not by generalized interest in development or study activity.
- A programmatic or regional EIS is not required unless the government has formulated a regional plan or program that constitutes major federal action.
- Courts should not compel anticipatory, region-wide EIS preparation when no regional proposal exists and environmental effects cannot be meaningfully assessed at that level of abstraction.
- NEPA is procedural: it requires informed consideration of environmental consequences at the point agency action is sufficiently definite, but it does not mandate particular substantive outcomes.

## Conclusion

The Court held that NEPA did not compel a single regional EIS for the Northern Great Plains because there was no concrete proposal for major federal action at the regional level; NEPA review must track actual proposed actions rather than speculative, study-based regional planning.


Kleppe v. Sierra Club, 427 U.S. 390 (1976)