Abstract

The Palisades Dam and Reservoir were constructed in 1956 pursuant to an Act of Congress and have since been continuously managed and controlled by the US Bureau of Reclamation. They are located between two other dams and reservoirs. The project controls and conserves the waters in the Snake River for fish, wildlife, recreation, irrigation, flood control, and power generation. Several Idaho sports organizations sued the Secretary of the Interior and the director of the Bureau of Reclamation to enjoin the Bureau's control over water flow from the dam. They contended that the Bureau was required to complete an environmental impact statement (EIS) before it reduced flow to less than 1,000 cubic feet per second. The trial court denied the request. The appellate court said an EIS is required for “major federal actions” that significantly affect the quality of the human environment, and that the Bureau's actions did not meet those conditions.

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