Akiak Native Community v. United States Postal Service

Plaintiffs, several Alaska Native communities, appeal from the district court’s summary judgment in favor of defendant, the United States Postal Service. Plaintiffs sought to enjoin the Postal Service’s Hovercraft Demonstration Project (“the Project”), an experimental program that delivers non-priority mail by surface hovercraft instead of by fixed-wing aircraft to eight remote Alaska Native villages on the Kus-kokwim River and two of its tributaries. Plaintiffs allege that the project violates the Coastal Zone Management Act (CZMA), 16 U.S.C. § 1456 , and the National Environmental Policy Act (NEPA), 42 U.S.C. § 4332 .

Plaintiffs contend that the Project violates CZMA because it is inconsistent with Alaska’s coastal management program. Plaintiffs argue that the Project violates NEPA because the Postal Service’s final Environmental Assessment contains errors, omissions, and failures of analysis that invalidate its “Finding of No Significant Impact.”

Because we find no infirmities under either CZMA or NEPA, we affirm the district court’s judgment.

Background and Procedural History

In response to an unsolicited suggestion of a cheaper means of delivering parcel mail to specified…