Pyramid Lake Paiute Tribe of Indians v. U.S. Department of the Navy 898 F.2d 1410 (9th Cir. 1990)) The Navy instituted an irrigation project on a base near the Truckee River. The project used a lot of water that would otherwise have been available downriver. Local environmental groups (led by the Paiute) sued for an injunction. The Paiute argued that the irrigation plan was inefficient, and the loss of water could affect endangered fish in Pyramid Lake. The Paiute argued that was a violation of the Endangered Species Act §7. The Trial Court found for the Navy. The Paiute appealed. The Trial Court found that while §7(a)(1) imposes an affirmative duty on non-Interior Federal agencies to use their authority to conserve endangered species, that duty does not rise to the level of duty imposed upon the Interior Department. The Court held that non-Interior agencies are entitled to "some discretion." The Appellate Court affirmed. The Appellate Court found that the Navy was not required to use the 'least burdensome alternative'. Compare to Sierra Club v. Glickman (156 F.3d 606 (1998)), which came to the opposite decision.