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A nonprofit conservation organization, Western Watersheds Project, filed a lawsuit challenging the Bureau of Land Management’s (BLM) decision to grant a 10-year grazing permit for four federal public land allotments for violating the National Environmental Policy Act (NEPA). In deciding to grant the permits, the BLM had filed an EA, but they had not includes in the EA a discussion of the “no action” alternative. The organiztion argued that the EA was defective without a discussion of the effects of the no action alternative. The BLM believed that they did not need to discuss the “no action” alternative because they were relying on the previously prepared Resource Management Plan determined that elimination of grazing was not viable or necessary option. The BLM noted that they had also examined two other alternatives. The District Court granted the BLM summary judgment. How do you believe the Court of Appeals ruled in this case, and why?

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