Sierra Club v. Dep't of Interior - 398 F. Supp. 284 (N.D. Cal. 1975)

Rule:

There is, in addition to these specific powers, a general trust duty imposed upon the National Park Service, Department of the Interior, by the National Park System Act, 16 U.S.C.S. § 1 et seq., to conserve scenery and natural and historic objects and wildlife in the National Parks, Monuments and reservations and to provide for the enjoyment of the same in such manner and by such means as will leave them unimpaired for the enjoyment of future generations.

Facts:

Defendant Secretary of the Interior and Department of the Interior conducted a series of studies of damage and threats of damage to the National Park caused by the logging operations of timber companies on adjacent lands. The studies resulted in many specific recommendations for steps to be taken by the Secretary to prevent or minimize such damage. The evidence showed that none of the recommendations were implemented, except for "cooperative agreements" with the timber companies to conduct further studies. Plaintiff environmentalists filed an action against defendant for declaratory and mandatory relief concerning the Secretary's alleged failure to discharge his statutory and fiduciary duty to protect a National Park from damage caused by logging operations on privately owned lands immediately adjacent to and surrounding certain portions of the park.

Issue:

Did the defendant fail to discharge his statutory and fiduciary duty to protect a National Park from damage caused by logging operations on privately owned lands immediately adjacent to and surrounding certain portions of the park, thereby warranting the grant of plaintiff’s motion for declaratory and mandatory relief? 

Answer:

Yes.

Conclusion:

The court held that the Secretary and Department unreasonably, arbitrarily and in abuse of discretion failed, refused and neglected to take steps to exercise and perform duties imposed upon them by the National Park System Act, 16 U.S.C.S. § 1, and the Redwood National Park Act, 16 U.S.C.S. § 79a. According to the court, the cooperative agreements entered into by the defendant with the timber companies were not contracts or cooperative agreements within the meaning of 16 U.S.C.S. § 79c(e) because only one had been signed by one of the timber companies, and none of them has been signed by the Secretary. They were, therefore, not legally binding contracts; and their language was so general and so full of qualifications as to render them practically meaningless and unenforceable for that reason as well. The court thus ordered that the Secretary and Department take reasonable steps to exercise and to perform the duties imposed upon them by the law.