Natural Resources Defense Council, Inc. v. Hodel 624 F.Supp. 1045 (1985), aff'd 819 F.2d 927 (9th Cir. 1987) The Bureau of Land Management (BLM) divided Federal lands into Planning Areas. Each Planning Area was further divided into allotments for which the BLM could issue a grazing permit. The BLM created a comprehensive gazing management plan for each Planning Area. It included a Management Framework Plan (MFP) and an Environmental Impact Statement (EIS). BLM felt that they did not have enough data to determine exactly how much grazing to allow, so they decided to not to adjust the amount of grazing permits until reliable data was available. The data did show that there was definitely overgrazing, so in essence, BLM was going to allow continuing overgrazing until they could figure out exactly how much grazing would be sustainable. Environmental groups, led by NRDC, sued for an injunction to stop the MFP for the Reno Planning Area. NRDC argued that the MFP was in conflict with various Statutes, and that it was arbitrary and capricious. Specifically the Taylor Grazing Act (TGA), Public Rangelands Improvement Act (PRIA), and Federal Land Policy and Management Act (FLPMA). NRDC argued that the MFP allowed overgrazing, and that was against the intention of TGA, PRIA, and FLPMA. The Trial Court found for the BLM. NRDC appealed. The Trial Court agreed that there was evidence of overgrazing, but that it couldn't be conclusively determined to be from BLM's grazing permits. The Court found that Congress had only put broad, discretionary language into TGA, PRIA, and FLPMA, and it would be difficult for a court to determine Agency compliance. The Court found that they should apply the Chevron Doctrine and defer to Agency expertise. See Chevron U.S.A. Inc. v. Natural Resources Defense Council (467 U.S. 837 (1984)). The Court noted that you could argue that BLM's plan to postpone adjusting the number of livestock grazing permits was less than ideal, but it was good enough that they couldn't be said to be arbitrary and capricious. The Court did not even order the BLM to do any data collection so that they might be able to come to a better decision in the future! The Appellate Court affirmed. The Appellate Court found that BLMs actions were not arbitrary and capricious. The Court found that there wasn't conclusive evidence of overgrazing, and the BLM didn't have sufficient data to make any decisions, so they should be allowed to continue the status quo. This case represents the apogee of judicial deference to BLM's decision-making process.