Habitat Education Center, Inc. v. U.S. Forest Service

Dist. Ct. did not err in lifting injunction that precluded defendant from going forward on two logging projects located in national forest even though plaintiff-environmental group alleged that defendant failed to take certain procedural steps required under National Environmental Policy Act before proceeding on said projects. Ct. rejected plaintiffs' contention that defendant failed to consider impact of future logging project when drafting supplemental environmental impact statement (SEIS) on current logging projects where: (1) draft of SEIS was made two months before future project was formally proposed; and (2) proposed future logging project would not have seriously changed environmental landscape presented in SEIS on current projects. Moreover, Ct. similarly determined that defendant did not err in failing to supplement environmental impact statement associated with current projects with analysis of future project where defendant had determined that future project did not have significant environmental impact on current projects, and where defendant would address impact of all three projects at time future logging project was formally considered. (Dissent filed.)