Center for Environmental Law & Policy v. United States Bureau of Reclamation

Lake Roosevelt in eastern Washington state serves a variety of purposes, including irrigation, navigation, flood control, power generation, recreation, and fish management. We consider here a challenge by environmental groups to a proposed incremental drawdown of water from the lake. As always, our review under the National Environmental Policy Act (“NEPA”), 42 U.S.C. § 4321 et seq., is limited to determining whether the agency, in this case the United States Bureau of Reclamation (“Reclamation”), took a “hard look” and genuinely scrutinized the environmental consequences of its proposed action. Our own close look at the record persuades us that Reclamation was keenly aware of, and appropriately discharged, this duty when it prepared the drawdown project analysis.

Background

The Columbia River forms the centerpiece of a basin that spans over 250,000 square miles of the United States and Canada. The river, which is home to numerous species of salmon and other fish, is controlled by a “complex and highly regulated system of ... dams and reservoirs.” These include the Grand Coulee Dam, which is located in eastern Washington, nearly 600 miles from the mouth of the Columbia…