Dine Citizens Against Ruining Our Env't v. Jewell

摘要

Federal district court did not abuse its discretion in denying preliminary injunction in lawsuit brought by environmental groups alleging Bureau of Land Management violated National Environmental Policy Act in authorizing permits to drill in San Juan Basin, because: (1) groups needed to show they were likely to succeed on merits of their claims to be entitled to injunctive relief, (2) groups did not establish that new horizontal drilling and multi-stage fracturing techniques would lead to greater environmental impacts than those anticipated in 2003 resource management plan and environ- mental impact statement that BLM tiered its individual permit approval environmental assessment NEPA analysis to, (3) groups did not establish how impacts from new drilling and fracturing techniques would be qualitatively different from those of prior analyzed techniques, and (4) groups did not establish that continued approval of new wells impermissi-bly limited BLM's options as it amends 2003 RMP.