ONRC Action v. Bureau of Land Management

Plaintiffs Oregon Natural Resources Council and other environmental organizations (collectively “ONRC”), appeal from the dismissal of their action against the Bureau of Land Management (“BLM”). ONRC filed suit under the Administrative Procedure Act (“APA”) claiming that BLM had violated the National Environmental Policy Act (“NEPA”) and the Federal Land Policy Management Act (“FLPMA”) by failing to halt certain actions pending completion of an Environmental Impact Statement (“EIS”). The district court found that ONRC did not identify any “final agency action” challengeable under the APA and dismissed ONRC’s action for lack of jurisdiction. We affirm the district court’s dismissal because we conclude that ONRC lacks standing under the APA to bring the present action.

I

On February 1, 1994, the Forest Service and BLM proposed to develop an ecosystem management strategy for forests and public lands (federal lands administered by BLM) east of the Cascade Mountains in Oregon and Washington (Eastside Ecosystem Management Strategy or “Eastside Management Plan”). This proposal was in response to President Clinton’s July 1993 mandate “to develop a scientifically sound and ecosystem-based…