Amicus Curiae Brief — Seven County Infrastructure Coalition, et al., Petitioners v. Eagle County, Colorado, et al.

No. 23-975

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In The

Supreme Court of the United States

---------------------------------♦--------------------------------SEVEN COUNTY INFRASTRUCTURE COALITION

and UINTA BASIN RAILWAY, LLC,

Petitioners,

v.

EAGLE COUNTY COLORADO and

CENTER FOR BIOLOGICAL DIVERSITY, et al.,

Respondents.

---------------------------------♦--------------------------------On Petition For A Writ Of Certiorari

To The United States Court Of Appeals

For The District Of Columbia Circuit

---------------------------------♦--------------------------------AMICUS CURIAE BRIEF OF

TN RANCHING COMPANY, RIO BLANCO

COUNTY COMMISSION OF RIO BLANCO

COUNTY, COLORADO, WHITE RIVER

CONSERVATION DISTRICT, DOUGLAS

CREEK CONSERVATION DISTRICT, AND

WYOMING STOCK GROWERS ASSOCIATION

IN SUPPORT OF PETITIONERS

---------------------------------♦--------------------------------KAREN BUDD-FALEN

300 East 18th Street

P.O. Box 346

Cheyenne, WY 82003-0346

(307) 632-5105

karen@buddfalen.com

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COCKLE LEGAL BRIEFS (800) 225-6964

WWW.COCKLELEGALBRIEFS.COM

i

TABLE OF CONTENTS

Page

TABLE OF CONTENTS ......................................

i

TABLE OF AUTHORITIES .................................

ii

INTEREST OF AMICUS CURIAE ......................

1

SUMMARY OF ARGUMENT ..............................

4

ARGUMENT ........................................................

5

A.

NEPA’s Command of Consistency Review

for Local Governments ..............................

7

B.

NEPA’s Command of Cooperating Agency

Status for Local Governments ................... 10

C.

Impacts of the Split in the Circuits on the

Regulated Public........................................ 15

CONCLUSION..................................................... 16

ii

TABLE OF AUTHORITIES

Page

CASES

Citizens Alert Regarding the Environment v.

United States Environmental Protection

Agency, 259 F. Supp.2d 9 (D.D.C. 2003)....................7

Department of Transportation v. Public Citizen,

541 U.S. 752 (2004) .......................... 1, 5-7, 10, 14, 15

Gulf Oil Corp. v. Gilbert, 330 U.S. 501 (1947) ..............5

Sierra Club v. FERC, 867 F.3d 1373 (D.C. Cir.

2017) ..........................................................................1

Western Watersheds Project et al. v. Secretary of

the Interior, 23-cv-02677 (D.D.C., filed September 12, 2023)......................................................15

Wyoming v. United States Dep’t of Interior, No.

07-CV-0319-B, 2008 WL 11335156 (D. Wyo.

Nov. 7, 2008), vacated sub nom. Wyoming v.

U.S. Dep’t of Interior, 587 F.3d 1245 (10th Cir.

2009) ..........................................................................4

STATUTES

42 U.S.C. § 4321 et seq. ........................................... 7, 12

42 U.S.C. § 4332(C) ................................................... 4, 6

Colo. Rev. Stat. § 30-11-101(k) ......................................8

Colo. Rev. Stat. § 35-70-102 ........................................11

Colo. Rev. Stat. § 35-70-108 ........................................11

Colo. Rev. Stat. § 35-70-108(1)(k) ...............................11

iii

TABLE OF AUTHORITIES—Continued

Page

OTHER AUTHORITIES

2024 Federal Policy Priorities | National Association of Counties (naco.org) (last viewed

April 3, 2024) .............................................................3

Council on Environmental Quality, “The Fourth

Report on Cooperating Agencies in Implementing the Procedural Requirements of the

National Environmental Policy Act (NEPA),”

October 2016, https://ceq.doe.gov/docs/ceqreports/Attachment-A-Fourth-CooperatingAgency-Report_Oct2016.pdf ...................................15

Lampe, Joanna (2024) Congressional Research

Service, Where a Suit can Proceed: Court Selection and Forum Shopping, LSB10856,

LSB10856 (congress.gov) (last visited April 3,

2024) ..........................................................................4

Land and Natural Resources Plan and Policies

in 2021. Updated LUP 2022ApprovedFinal_

0.pdf (colorado.gov) ...................................................8

REGULATIONS

40 C.F.R. § 1501.7(h) (2023) .......................................13

40 C.F.R. § 1501.7(i) (2023)................................... 13, 14

40 C.F.R. § 1501.8 (2023) ............................................14

40 C.F.R. § 1501.8(a) (2023) ........................................10

40 C.F.R. § 1502.16(a)(5) (2023) ...................................7

40 C.F.R. § 1502.16(b) (2023) ........................................8

iv

TABLE OF AUTHORITIES—Continued

Page

40 C.F.R. § 1506.2(d) (2023)..........................................8

40 C.F.R. § 1508.1(ee) (2023) ......................................10

40 C.F.R. § 1508.1(g)(2) (2023) .....................................6

1

INTEREST OF AMICUS CURIAE1

Amicus TN Ranching Company, owned by Butch

and Jeannie Jensen, is a 5th generation family owned

and operated ranch located near Price, Utah. The

ranch owns approximately 1,200 head of livestock

which graze more than 13,000 “animal unit months2”

of forage on their allotments located on lands managed

by the U.S. Department of the Interior, Bureau of Land

Management (“BLM”). Each of TN Ranching Co.’s term

grazing permits granted by the BLM is subject to analysis under the National Environmental Policy Act

(“NEPA”). As such, the determination of what is an “indirect effect” as defined under the analysis of Department of Transportation v. Public Citizen, 541 U.S. 752

(2004) (Public Citizen) compared with the analysis under Sierra Club v. FERC, 867 F.3d 1373 (D.C. Cir. 2017)

has a direct impact on TN Ranching Co.’s livelihoods

as the loss of their term grazing permits would decimate their livestock operation and livelihood. Additionally, the Uintah Basin Railway runs through a

portion of TN Ranching Co.’s private property and

through their BLM grazing allotments.

1

Rule 37 statement: The parties were notified and consented

to the filing of this brief no more than 10 days before its filing. See

Sup. Ct. R. 37.2. No party’s counsel authored any of this brief;

amicus alone funded its preparation and submission. See Sup. Ct.

R. 37.6.

2

An animal unit month (“AUM”) is the amount of forage consumed by one animal (e.g., cow and her calf or yearling cow) on

lands managed by the U.S. Forest Service or BLM. Livestock grazing permits in the United States on federal lands allow the grazing of a specific number of AUMs based on the size of the grazing

allotment, type of livestock and time period of the year specified

in the grazing permit.

2

Amicus Rio Blanco County Commission of Rio

Blanco County, Colorado, is located in northwestern

Colorado (Rio Blanco). Amici White River Conservation District and the Douglas Creek Conservation District (collectively “local governments”) are located

within Rio Blanco County, Colorado. Rio Blanco

County contains approximately 2,064,000 acres of

land, 56 percent of which is managed by the BLM, 24

percent is privately owned, and 17 percent is managed

by the United States Forest Service. The incorporated

areas of Rangely and Meeker in Rio Blanco County

consist of approximately two percent of the land base,

and the State of Colorado owns less than one percent

of the land in the County. Because of the significant

amount of federally managed land within the boundaries of these units of local government, they are intricately impacted by federal agency decisions and their

accompanying analyses under NEPA. Additionally, because NEPA grants to local governments additional

opportunities to participate in the NEPA process above

and beyond the opportunity to provide public comment, local governments will be hampered in participating in their additional regulatory processes unless

there is a clear consistent definition and analysis of

what is included as an “indirect affect.”

Amicus, the Wyoming Stock Growers Association

(“WSGA”) was organized on April 4, 1872, to advance

and protect the interest of the state’s livestock producers. It was the second state cattlemen’s organization

created in the United States. Wyoming Stock Growers

was the first association formed in the Wyoming

3

territory. It is the only organization in the state focused

entirely on serving the needs of the cattle industry,

which is the largest segment of Wyoming’s agricultural

production. The mission of the Wyoming Stock Growers Association is to serve the livestock business and

families of Wyoming by protecting their economic, legislative, regulatory, judicial, environmental, custom,

and cultural interests. The Wyoming Stock Growers

Association advocates for the protection of private

property rights from overly burdensome regulatory interference. The Association maintains a legal fund to

enable it to initiate, defend or support litigation on critical issues with the potential to have a major impact

on its members’ ranching enterprises.

The amici curiae represent both local governments as described in the implementing regulations

under the NEPA and agricultural landowners reliant

on their federal lands grazing permits, which have to

be evaluated under NEPA. Sixty two percent of counties in the United States have federal public lands

within their borders. 2024 Federal Policy Priorities |

National Association of Counties (naco.org) (https://

www.naco.org/resource/2024-federal-policy-priorities#:

~:text=Sixty-two%20percent%20of%20counties,have

%20federal%20public%20land) (last viewed April 3,

2024). These parties bring a unique perspective on the

question before this Court because they are directly affected by the various courts’ conflicting determinations

of what is included as an “indirect effect.”

---------------------------------♦---------------------------------

4

SUMMARY OF ARGUMENT

The purpose of this brief is to illustrate the difficulties that a split in the circuits has on local governments and agricultural interests in determining the

breadth of “indirect effects” under the NEPA. Local

governments, such as those represented by amici, are

granted specific and important opportunities to participate with federal agencies in preparing and analyzing

documents prepared pursuant to the NEPA. These specific opportunities include developing local land use

plans which have to be specifically and separately considered by a federal agency in making its final decision.

Agricultural operations that are absolutely dependent

on the use of the federal lands to continue their livelihoods are also directly impacted by this split in the circuits, particularly when those challenging a decision

can either challenge the final decision in a federal district court in the circuit in which the permit is granted,

or in the D.C. District Court. It should not be a “race to

the courthouse” to challenge a decision based upon an

alleged failure to properly analyze “indirect effects”

based upon differing circuit court determinations.

See Lampe, Joanna (2024) Congressional Research

Service, Where a Suit can Proceed: Court Selection and

Forum Shopping, LSB10856, LSB10856 (congress.gov)

(https://crsreports.congress.gov/product/pdf/LSB/LSB

10856) (last visited April 3, 2024).

Yet that is often what happens in these cases. See

e.g. Wyoming v. United States Dep’t of Interior, No. 07CV-0319-B, 2008 WL 11335156, at *2 (D. Wyo. Nov. 7,

2008), vacated sub nom. Wyoming v. U.S. Dep’t of

5

Interior, 587 F.3d 1245 (10th Cir. 2009) (stating that

“Initially, this Court finds it unfortunate that a United

States District Court [the D.C. District Court] sitting

over 2,000 miles away from the actual subject of this

litigation feels compelled to hand down a ruling affecting land that lies in this Court’s backyard [Federal District Court for the District of Wyoming]. As the United

States Supreme Court has stated, ‘In cases which

touch the affairs of many persons, there is reason for

holding the trial in their view and reach rather than in

remote parts of the country where they can learn of it

by report only. There is a local interest in having localized controversies decided at home.’ ” Gulf Oil Corp. v.

Gilbert, 330 U.S. 501, 509 (1947). However, depending

upon whether the plaintiff wishes the court to reject an

analysis under NEPA for failing to consider impacts

over which the agency has no authority or jurisdiction

to consider can be the deciding factor whether to file in

the D.C. District Court rather than a federal district

court in the Eleventh, Sixth, Fourth or Seventh Circuits. Amici would urge the U.S. Supreme Court to accept certiorari in this case to remedy this split in the

circuits, end the “race to the courthouse” and ensure

that the D.C. Circuit Court and the Ninth Circuit

Court comply with the plain meaning of Public Citizen.

---------------------------------♦---------------------------------

ARGUMENT

According to NEPA, all federal agencies shall

prepare an environmental impact statement (“EIS”)

or an environmental assessment (“EA”), (i.e., a NEPA

6

document) for “every recommendation or report on

proposals for legislation and other major Federal actions significantly affecting the quality of the human

environment. . . .” 42 U.S.C. § 4332(C). Such EIS or EA

shall analyze the direct, indirect and cumulative effects of the proposed agency actions. 40 C.F.R.

§ 1508.1(g)(2) (2023). Under this court’s decision in

Public Citizen, consideration of such direct, indirect

and cumulative effects stops where the agency’s statutory authority stops; in other words, an indirect action

is one that would occur “but for” the proposed federal

action. In contrast, the D.C. Circuit Court and the

Ninth Circuit Court require agencies to go further and

analyze any effect that is “reasonably foreseeable.” The

Petitioners’ Petition for Writ of Certiorari thoroughly

discusses this issue.

What this brief would focus on, however, is the impact of this split in the circuit courts on local governments who also have the ability to participate in the

NEPA analysis process, including providing analysis

on direct, indirect and cumulative impacts. Such local

government participation includes both “consistency

review” between the federal agency land use plans, decisions and programs and the local government’s local

land use or policy plan. Local governments can also be

granted “cooperating agency status” from the federal

agencies pursuant to NEPA. For agriculturalists,

whose livelihoods depend on being able to use their

federal lands grazing allotments, this split in interpretation causes a “race to the courthouse” once the NEPA

review of their term grazing permits is released,

7

meaning that a term grazing permit impacting TN

Ranching Co. or members of the Wyoming Stock Growers Association can be challenged in Washington D.C.,

2000 miles away from the impact of the decision in

hopes of a different outcome based on the D.C. Circuit’s

outside interpretation of Public Citizen.

A. NEPA’s Command of Consistency Review

for Local Governments

NEPA applies to all agencies of the federal government and requires an environmental analysis for all

“major federal actions significantly effecting the human environment.” 42 U.S.C. § 4321 et seq. The courts

have traditionally adopted a very broad interpretation

of when NEPA applies, meaning that every time the

federal government makes a decision for almost any

action that may have an environmental impact, NEPA

compliance is required. See e.g., Citizens Alert Regarding the Environment v. United States Environmental

Protection Agency, 259 F. Supp.2d 9, 20 (D.D.C. 2003).

With regard to the mandate for a “consistency review,” the NEPA regulations require that the environmental consequences section of an EIS shall include

“possible conflicts between the proposed action and the

objectives of Federal, Regional, State, Tribal and local

land use plans, policies, and controls for the area concerned.” 40 C.F.R. § 1502.16(a)(5) (2023). Additionally,

an EIS must discuss any “inconsistency of a proposed

plan with any approved State or local plan and laws

(whether or not federally sanctioned).” 40 C.F.R.

8

§ 1506.2(d) (2023). Where inconsistencies exist, the

EIS should describe the extent to which the agency

would reconcile its proposed action to the local government’s plan, policy, control or law. Id.

The environmental consequences section of the

EIS shall also include economic and technical considerations “including economic benefits of the proposed

action.” 40 C.F.R. § 1502.16(b) (2023). The regulations

note that while economic and social considerations, in

and of themselves, do not require the preparation of an

EIS, when economic or social effects are interrelated

with environmental effects, the EIS shall discuss and

consider economic and social effects. Id. Finally, NEPA

commands that copies of comments by State or local

governments must accompany the EIS or EA throughout the review process. 42 U.S.C. § 4332(C).

To take advantage of NEPA’s regulatory requirements requiring consistency with local plans or policies, numerous local governments such as counties and

conservation districts have adopted local land use

plans specifically for the purpose of consistency review.

For example, amici Rio Blanco County Colorado and

the Douglas Creek and White River Conservation Districts (collectively local governments) adopted their

Land and Natural Resources Plan and Policies in 2021.

Updated LUP 2022ApprovedFinal_0.pdf (https://wrcddccd.colorado.gov/sites/wrcd-dccd/files/documents/

Updated%20LUP%202022ApprovedFinal_0.pdf) (colorado.gov). This local land use plan was specifically

written in light of NEPA’s requirement to:

9

As required by the National Environmental Policy Act (NEPA), the Federal Land Policy

and Management Act (FLPMA), the National

Forest Management Act (NFMA) and other

federal statutes, this Plan will be applied to

federal regulatory frameworks that govern

the management of federal land in regard to

the rangeland, soil, water, wildlife, air, energy,

and other resources. For example, Federal law

requires federal agencies to give meaningful

consideration to policies asserted in plans developed by local governments, including counties and conservation districts.

Id. at 1.

Amici local governments’ local land use plan discusses the local governments’ positions relating to the

need for credible data, county history, customs and culture3, federal land management policies, air quality

policies, climate change policies, forest management,

wildfire and community wildfire planning, livestock

grazing, noxious weeds and invasive species, oil, gas,

coal and minerals, socioeconomic and economic viability of the local area, soils, special designation areas and

scenic byways/viewsheds, travel management, access

and recreation, water—rights and use, wild and scenic

3

Culture is defined as the customary beliefs, social forms

and material traits of a group; an integrated pattern of human

behavior passed to succeeding generations. Webster’s New Collegiate Dictionary, 277 (1975). A custom is a usage or practice of the

people, which, by common adoption and acquiescence, and by long

and unvarying habit, has become compulsory and has acquired

the force of law with respect to the place or subject-matter to

which it relates. Bouvier’s Law Dictionary, 417 (1st ed. 1867).

10

river designations, wild horses, burros and estray livestock, and wildlife management. Because these local

governments are within the Tenth Circuit of Appeals,

the local governments analyzed the potential direct,

indirect and cumulative effects of possible federal

agency actions based on the requirements of Public

Citizen. However, if litigation over a federal decision in

which a federal agency completed a “consistency review” is brought in the D.C. District Court, the effort of

the local government to write a plan consistent with

Public Citizen is all for naught simply based on where

the litigation is brought. This is a significant disadvantage to local government’s participation in the

NEPA analysis because the local land use plan will

never be consistent.

B. NEPA’s Command of Cooperating Agency

Status for Local Governments

Cooperating agency status also gives local governments the ability to participate as part of a federal

agency’s decision-making process. Pursuant to NEPA,

an applicant for cooperating agency status must be

both (1) an elected body such as a conservation district

board of supervisors or a county commission and (2)

possess “special expertise.” “Special expertise is defined as the statutory responsibility, mission or related

program experience of the local governing body.” 40

C.F.R. § 1508.1(ee) (2023). A State, Tribal or local

agency of similar qualifications may, by agreement of

the lead agency, become a cooperating agency. 40 C.F.R.

§ 1501.8(a) (2023). For example, under the Colorado

11

state statutes, the White River and Douglas Creek

Conservation Districts are made up of locally elected

officials whose special expertise is to provide leadership in the wise use of the natural resources within the

Districts’ boundaries. Conservation districts in Colorado are defined as “local governments” and have the

ability to participate in government-to-government interactions with the federal agencies. The Districts

within Rio Blanco County have developed their Land

& Natural Resource Use Plan and Policy to translate

their statutory mandate (Colo. Rev. Stat. § 35-70-108)

into land management policy and direction for federal

agencies to consider.

For example, one of the Districts’ responsibilities

is: “To prepare a plan for the care, treatment, and operation of the lands within the district.” Colo. Rev. Stat.

§ 35-70-108(1)(k). Additionally, Colorado conservation

districts were created by the state legislature to provide for constructive methods of land use providing for

the conservation and preservation of natural resources, including adequate underground water reserves, the control of wind and water erosion, and the

reduction of damage resulting from floods. The purposes of the conservation districts are to “insure the

health, prosperity, and welfare of the state of Colorado

and its people . . . ” Colo. Rev. Stat. § 35-70-102.

Similarly, by state statute, Colorado county governments, like Rio Blanco County, are also local governments with special expertise. In fact, Colorado

statutes allow local governments to:

12

Coordinate, pursuant to 43 U.S.C. sec. 1712,

the “National Environmental Policy Act of

1969”, 42 U.S.C. sec. 4321 et seq., 40 U.S.C. sec.

3312, 16 U.S.C. sec. 530, 16 U.S.C. sec. 1604,

and 40 C.F.R. parts 1500 to 1508, with the

United States secretary of the Interior and

the United States secretary of Agriculture to

develop land management plans that address

hazardous fuel removal and other forest management practices, water development and

conservation measures, watershed protection,

the protection of air quality, public utilities

protection, and private property protection on

federal lands within such county’s jurisdiction.

Colo. Rev. Stat. § 30-11-101(k).

Thus, based on these statutory authorities, the

policies and powers of these local governments encompass the obligation to protect the customs and culture

of the local citizens, to provide for community stability,

and to protect the natural environment and resources

as cooperating agencies.

In addition to stating that federal agencies shall

consider local governments as cooperating agencies,

NEPA regulations specify the procedures regarding

the same. With respect to cooperating agencies, NEPA

regulations state that the lead agency shall:

(1) Request participation in the NEPA process at the earliest practicable time.

(2) Use the environmental analysis and proposals of cooperating agencies with

13

jurisdiction by law or special expertise, to

the maximum extent practicable.

(3) Meet with a cooperating agency at the

latter’s request.

(4) Determine the purpose and need, and alternatives in consultation with a cooperating agency.

40 C.F.R. § 1501.7(h) (2023).

The lead agency shall develop a schedule, set milestones for environmental reviews in consultation with

all lead, cooperating and participating agencies as soon

as practicable. 40 C.F.R. § 1501.7(i) (2023). With regard

to cooperating agencies, the regulations require:

(b)

Each cooperating agency shall:

(1) Participate in the NEPA process at

the earliest practicable time.

(2) Participate in the scoping process

(described in § 1501.9).

(3) On request of the lead agency, assume responsibility for developing information

and

preparing

environmental

analyses, including portions of the environmental impact statement or environmental

assessment concerning which the cooperating

agency has special expertise.

(4) On request of the lead agency, make

available staff support to enhance the lead

agency’s interdisciplinary capability.

14

(5) Normally use its own funds. To the

extent available funds permit, the lead agency

shall fund those major activities or analyses it

requests from cooperating agencies. Potential

lead agencies shall include such funding requirements in their budget requests.

(6) Consult with the lead agency in developing the schedule (§ 1501.7(i)), meet the

schedule, and elevate, as soon as practicable,

to the senior agency official of the lead agency

any issues relating to purpose and need, alternatives, or other issues that may affect any

agencies’ ability to meet the schedule.

(7) Meet the lead agency’s schedule for

providing comments and limit its comments

to those matters for which it has jurisdiction

by law or special expertise with respect to any

environmental issue consistent with § 1503.2

of this chapter.

(8) To the maximum extent practicable,

jointly issue environmental documents with

the lead agency.

40 C.F.R. § 1501.8 (2023).

Because of the split in the circuits related to the

required analysis in Public Citizen, participation in the

scoping process is minimized if the federal agency and

local government have to try to figure out how broad

the “indirect effects” are depending on where they anticipate litigation will be filed. To ensure that directly

impacted federal agencies and local governments can

comply with NEPA, the D.C. Circuit and the Ninth

15

Circuit should be required to interpret Public Citizen

as this Court plainly stated.

C. Impacts of the Split in the Circuits on the

Regulated Public

The impact of the split in the circuits over the

basic tenants of the breath of the issues in a NEPA document also significantly affects the regulated public

such as TN Ranching Co. and members of the Wyoming

Stock Growers Association. According to the Council of

Environmental Quality, approximately 12,000 substantive environmental reviews under NEPA are completed by the federal agencies each year. See Council

on Environmental Quality, “The Fourth Report on Cooperating Agencies in Implementing the Procedural

Requirements of the National Environmental Policy

Act (NEPA),” October 2016, https://ceq.doe.gov/docs/

ceq-reports/Attachment-A-Fourth-Cooperating-AgencyReport_Oct2016.pdf. Although BLM grazing permits,

like the ones held by TN Ranching Co. and the members of the Wyoming Stock Growers Association, are

renewed every 10 years, the BLM manages approximately 18,000 such permits, meaning that the BLM

has to complete 1,800 NEPA analyses and permit renewal decisions each year on grazing alone. Because

complying with NEPA is getting increasingly difficult

based on the massive amount of litigation that is filed,

the BLM is behind on their renewal process and litigation has been filed alleging the court must order the

BLM to rectify the backlog and complete the NEPA

process for grazing permit renewal. See Western

16

Watersheds Project et al. v. Secretary of the Interior,

23-cv-02677 (D.D.C., filed September 12, 2023) (WWP

litigation). While the WWP litigation does not allege

a violation of failure to adequately consider indirect

impacts, the resulting NEPA analysis for the amici

grazing permits will individually involve an analysis

of “indirect effects” and whether such analysis by the

lead federal agency and cooperating agencies is upheld will depend on where any final decision is challenged.

---------------------------------♦---------------------------------

CONCLUSION

WHEREFORE, amici respectfully request that

the Supreme Court grant the Petition for Writ of Certiorari.

Respectfully submitted,

KAREN BUDD-FALEN

BUDD-FALEN LAW OFFICES

300 East 18th Street

P.O. Box 346

Cheyenne, WY 82003-0346

(307) 632-5105

karen@buddfalen.com

April 5, 2024