Andrus v. Sierra Club

Background

Three environmental organizations—the Sierra Club, the National Parks and Conservation Association, and the Natural Resources Defense Council—sued the Secretary of the Interior and the Director of the Office of Management and Budget. They challenged cuts proposed to the National Wildlife Refuge System’s budget and argued that those appropriation requests should have been accompanied by environmental impact statements under NEPA §102(2)(C). The District Court agreed and ordered EISs; the Court of Appeals narrowed that rule to certain new or programmatic funding changes. The Supreme Court granted review.

Reasoning

The Court considered whether NEPA’s requirement for a “detailed statement” applies to appropriation requests. It relied on the Council on Environmental Quality’s finalized regulations, traditional distinctions between legislation and appropriations, and practical concerns about timing and confidentiality in the budget process. The Justices explained that appropriation requests fund actions rather than propose them and that requiring EISs for routine budget submissions would be redundant or unworkable. The Court therefore concluded appropriation requests are neither “proposals for legislation” nor “major Federal actions” under §102(2)(C), and reversed the Court of Appeals.

Real world impact

The decision means federal agencies generally do not need to attach environmental impact statements to ordinary budget or appropriation requests. Agencies must still prepare EISs when they make actual programmatic proposals or take major actions that significantly affect the environment. The ruling prevents a broad requirement that could have generated many EISs during the routine budget cycle and preserves the separation between funding decisions and legislative policy choices.