National Wildlife Federation v. Bureau of Land Management (The Comb Wash Case) 140 IBLA 85 (1997) The Bureau of Land Management (BLM) created a Resource Area in Utah (which included a river called Comb Wash). BLM developed a Resource Management Plan (RMP) and an Environmental Impact Statement to determine how best to use the area. The EIS had a number of deficiencies. It did not provide detailed information needed to determine if grazing in the area was environmentally harmful, it did not contain an analysis of the grazing plan being implemented, it did not contain information on the current condition of the area, and it lacked discussion on the relative values of resources in the area or provide a balancing of the harms and benefits of grazing. BLM issued a number of grazing permits. Environmental groups (led by NWF) sued for an injunction. NWF argued that BLM failed to follow the requirements of Federal Land Policy and Management Act (FLPMA) and the National Environmental Policy Act (NEPA) when they issued the permits. NWF argued that BLM's decision was arbitrary and capricious and therefore the courts should not give it deference. The Administrative Law Judge granted the injunction. BLM appealed. BLM admitted that they had made some mix-ups and thought that a binding decision to graze had already been made, therefore the EIS did not require them to consider alternatives. The Interior Board of Land Appeals (IBLA) affirmed. IBLA found that FLPMA's multiple use mandate requires that BLM balance competing resource values to ensure that public lands are managed in the manner "that will best meet the present and future needs of the American people." IBLA found that since BLM had failed to engage in any reasoned or informed decision-making process their actions were arbitrary and capricious. IBLA remanded back to BLM to actually do a competent EIS and RMP.