## Facts

- Atlantic Coast Pipeline LLC proposed a roughly 604-mile natural gas pipeline from West Virginia to North Carolina.
- Approximately 16–21 miles would cross the George Washington and Monongahela National Forests.
- A short segment would pass beneath the Appalachian National Scenic Trail where the Trail crosses the George Washington National Forest, with the pipe routed underground well below the Trail.
- The U.S. Forest Service (USFS) issued a special use permit and granted a pipeline right-of-way under the Mineral Leasing Act (MLA) for the crossing.
- The Appalachian Trail is a “national scenic trail” administered by the Secretary of the Interior, with administration delegated to the National Park Service (NPS).
- The MLA authorizes pipeline rights-of-way across certain federal lands, including national forests, but bars rights-of-way “through any Federal lands in the National Park System.”
- Environmental and local organizations challenged the permit, arguing that NPS administration of the Trail makes the land the Trail traverses “land in the National Park System,” removing USFS authority under the MLA.

## Issues

1. Whether NPS administration of the Appalachian Trail converts the underlying land the Trail traverses into “Federal lands in the National Park System” for purposes of the MLA.
2. Whether USFS has authority under the MLA to grant a natural-gas pipeline right-of-way beneath the Appalachian Trail where the Trail crosses National Forest System land.

## Decision

- The Supreme Court reversed the Fourth Circuit in a 7–2 decision.
- The Court held that assigning NPS administrative responsibility for the Appalachian Trail did not transform the underlying land into National Park System land.
- Because the land at issue remained National Forest System land, USFS had authority under the MLA to issue the special use permit and right-of-way.
- The case was remanded for further proceedings consistent with the Court’s holding.

## Legal Principles

- A “trail” under the National Trails System Act is treated as a right-of-way across land, not the land itself; trail administration does not itself change the legal status of underlying lands.
- Delegating administration of a national scenic trail to NPS does not transfer jurisdiction over, or reclassify, federal land managed by another agency.
- The MLA’s prohibition on pipeline rights-of-way through “Federal lands in the National Park System” applies to land that is actually part of the National Park System; it does not reach National Forest System land merely because a trail administered by NPS crosses it.
- Courts should not infer major changes in federal land status and inter-agency jurisdiction from indirect statutory references absent clear congressional direction.

## Conclusion

The Court concluded that NPS administration of the Appalachian Trail concerns management of the trail right-of-way rather than reclassification of the land beneath it, so the MLA did not bar USFS from authorizing a pipeline right-of-way under the Trail where it crosses national forest land.


U.S. Forest Serv. v. Cowpasture River Pres. Ass'n, 140 S. Ct. 1837 (2020)