Native Ecosystems Council v. Tidwell

The United States Ninth Circuit Court of Appeals held that the U.S. Forest Service‟s proxy-on-proxy approach, when considering livestock grazing levels in Southwest Montana‟s Antelope Basin/Elk Lake Project in the Beaverhead-Deerlodge National Forest, did not comply with the National Forest Management Act. The court determined that the Forest Service failed to take a requisite “hard look” at environmental impacts, such as the impacts on sage grouse populations and the maintenance of diverse habitats for native wildlife, when it approved grazing allotment updates.