Plaintiffs Western Watersheds Project, Hells Canyon Preservation Council, and The Wilderness Society file this emergency motion for injunctive relief seeking an immediate closure of the Bureau of Land Management’s (“BLM”) Partridge Creek allotment—which is scheduled to be grazed October 15—to protect the struggling bighorn sheep populations that inhabit the Salmon River canyon. The Partridge Creek allotment is sandwiched between Forest Service allotments that have been closed to domestic sheep grazing for three years because of the risk of disease transmission from domestic sheep to bighorn sheep; but BLM refuses to take similar action, thus threatening the only remaining native bighorn sheep in the state with disease.
Recent scientific analysis shows that the Partridge Creek allotment contains extensive bighorn sheep habitat and is within the home range of the Salmon River canyon bighorn population. Recent telemetry locations and other observations of bighorn sheep show that they consistently use habitat near or on the Partridge Creek allotment. The Forest Service determined that such information warranted closure of the adjacent allotments to protect bighorn sheep while it conducted long-term environmental analyses, but BLM is taking the opposite approach. By refusing to close this allotment while it assesses the impacts to bighorn sheep from continued grazing, BLM is violating the National Environmental Policy Act (“NEPA”) and the Federal Land Policy and Management Act (“FLPMA”), and is threatening these native bighorn sheep with imminent irreparable harm. Thus, the Court should grant Plaintiffs’ motion and immediately enjoin grazing on this allotment until BLM completes its environmental analysis.
Partridge Creek Allotment
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Brief in Support of Plaintiff’s Emergency Motion for TRO and/or Preliminary Injunction
Second Amended Complaint
Fifth Declaration of Victor L. Coggins
Fifth Declaration of Lauren M. Rule