## Facts

- Environmental organizations challenged the Bureau of Land Management’s (BLM) livestock-grazing management framework plan (MFP) for the Reno Grazing District and its accompanying environmental impact statement (EIS).
- The relevant statutory framework included the Federal Land Policy and Management Act (FLPMA), which directs multiple-use, sustained-yield management of public lands, and the Public Rangelands Improvement Act (PRIA), which seeks improved conditions on degraded public rangelands.
- The MFP set broad rangeland objectives and methods, prioritized range improvements and grazing systems on the most degraded lands, and contemplated reductions in livestock numbers over time rather than immediate, across-the-board reductions.
- The EIS compared the proposed plan with alternatives but did not include site-specific grazing-capacity estimates or parcel-by-parcel prescriptions; those details were left to later, permit-level implementation decisions.
- Plaintiffs argued BLM unlawfully failed to require immediate, specific stocking-rate reductions and that NEPA required site-specific analysis at the planning stage.
- The case was decided on cross-motions for summary judgment.

## Issues

1. Whether PRIA and FLPMA required BLM, at the MFP stage, to impose specific, immediate livestock reductions and detailed prescriptions to correct degraded rangeland conditions.
2. Whether NEPA required the EIS for the MFP to include site-specific grazing-capacity estimates and detailed, allotment-level environmental analysis rather than deferring detail to later permitting decisions.

## Decision

- The district court entered judgment for the defendants and upheld the MFP and EIS.
- The court held that PRIA and FLPMA did not compel the specific, immediate, and detailed grazing reductions sought by plaintiffs at the planning level.
- The court held the EIS satisfied NEPA as a programmatic review that reasonably analyzed the plan and alternatives, with site-specific matters reserved for later actions.
- The Ninth Circuit affirmed.

## Legal Principles

- Under APA review, courts do not substitute their judgment for an agency’s technical and policy determinations in land-management programs absent arbitrariness, capriciousness, or legal error.
- PRIA and FLPMA state broad improvement and multiple-use objectives but leave BLM substantial discretion regarding methods, timing, and level of detail in land-use planning documents.
- NEPA permits programmatic EISs that analyze a broad plan and alternatives without exhausting site-specific detail, where later implementation decisions will address localized impacts.
- “Tiering” environmental review—using a general programmatic EIS followed by more specific analysis at later stages—can satisfy NEPA when the initial EIS provides a reasonably thorough discussion of impacts and options.

## Conclusion

The courts sustained BLM’s Reno grazing planning approach, concluding that rangeland-improvement statutes did not require immediate, highly specific prescriptions at the program-planning stage and that NEPA was satisfied by a programmatic EIS that deferred allotment-level detail to subsequent permitting decisions.


Nat. Res. Def. Council, Inc. v. Hodel, 624 F. Supp. 1045 (D. Nev. 1985), aff'd, 819 F.2d 927 (9th Cir. 1987)