Summary
The U.S. District Court for the District of Columbia considers environmental groups’ challenge to the Department of the Interior and Bureau of Land Management’s approval of the Converse County Oil and Gas Project in Wyoming. The court holds that BLM violated NEPA by failing to adequately analyze reasonable alternatives, including paced development and targeted greenhouse-gas mitigation. The court grants plaintiffs’ summary judgment motion, denies as moot motions to dissolve the injunction, and denies leave to file a second amended complaint.
Court
United States District Court for the District of Columbia
Jurisdiction
United States District Court for the District of Columbia
Decision date
February 27, 2026
Docket number
Civil Action No. 2022-2696 (TSC)
Disposition
vacated
Questions Presented
- Whether Plaintiffs' remaining challenges to the 2020 Converse County EIS and ROD were moot after BLM issued supplemental groundwater analyses and reaffirmed the Project approval.
- Whether BLM violated NEPA by eliminating from detailed study a reasonable alternative involving a slower or paced rate of development.
- Whether BLM violated NEPA by failing to adequately consider a standalone alternative involving direct greenhouse-gas reduction and mitigation measures.
- Whether the 2020 EIS and ROD should be vacated and remanded rather than remanded without vacatur.
- Whether Plaintiffs should be permitted to supplement or amend the complaint to add claims challenging later BLM environmental documents and permit approvals.
Holdings
- Plaintiffs' remaining claims were not moot because BLM's later supplemental environmental documents reaffirmed and incorporated the 2020 EIS and ROD rather than correcting or superseding the challenged environmental analysis.
- BLM violated NEPA by eliminating from detailed study a reasonable alternative that would have limited or paced the rate of well development.
- BLM violated NEPA by eliminating a reasonable alternative involving direct greenhouse-gas mitigation without adequately considering feasible measures short of carbon-neutral operations or total elimination of venting and flaring.
- The 2020 Converse County EIS and ROD must be vacated and remanded to BLM for further consideration.
- Plaintiffs' motion for leave to file a second amended complaint was denied because the proposed claims concerned separate, later agency actions and would radically alter the scope and nature of the litigation, causing delay and prejudice.
Court Document
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