TULELAKE IRRIGATION DISTRICT V. USFWS, No. 20-35515 (9th Cir. 2022)
Annotate this Case
Tulelake Irrigation District and associated agricultural groups (collectively “TID”) alleged that, in imposing restrictions on the agricultural uses of lease land in the Tule Lake and Lower Klamath Refuges in the Klamath Basin National Wildlife Refuge Complex in southern Oregon and northern California, the Service violated environmental laws.
On appeal, TID argued that the Service violated the Kuchel Act of 1964 and the National Wildlife Refuge System Improvement Act as amended by the Refuge Improvement Act (“Refuge Act”). TID argued that in approving the combined Environmental Impact Statement and Comprehensive Conservation Plan (“EIS/CCP”) for five of the six wildlife refuges in the Klamath Refuge Complex, the Service misconstrued the Kuchel Act to require the Service to regulate uses of leased agricultural land in the two refuges to ensure that the uses were “consistent” with “proper wildfowl management.” 16 U.S.C. Section 695n.
The Ninth Circuit rejected TID’s interpretation of Section 695n. The court held that with respect to the textual argument made by TID, the language of Section 695n, whether considered in isolation or in the context of the rest of the Kuchel Act, was unambiguous. The court held that it did not, therefore, need to proceed to step two of the Chevron analysis. The court concluded that the Kuchel Act required the Service to regulate the pattern of lease land agriculture in the refuges to ensure consistency with proper waterfowl management. The court further held that the regulation in the EIS/CCP of agricultural uses of lease land was a proper exercise of the Service’s authority under the Kuchel and Refuge Acts.
Court Description: Environmental Law. The panel affirmed the district court’s summary judgment to the U.S. Fish and Wildlife Service (the “Service”) in an action brought by Tulelake Irrigation District and associated agricultural groups (collectively “TID”) alleging that, in imposing restrictions on the agricultural uses of lease land in the Tule Lake and Lower Klamath Refuges in the Klamath Basin National Wildlife Refuge Complex in southern Oregon and northern California, the Service violated environmental laws. On appeal, TID argued that the Service violated the Kuchel Act of 1964 and the National Wildlife Refuge System Improvement Act as amended by the Refuge Improvement Act (“Refuge Act”). First, TID argued that in approving the combined Environmental Impact Statement and Comprehensive Conservation Plan (“EIS/CCP”) for five of the six wildlife refuges in the Klamath Refuge Complex, the Service misconstrued the Kuchel Act to require the Service to regulate uses of leased agricultural land in the two refuges to ensure that the uses were “consistent” with “proper wildfowl management.” 16 U.S.C. § 695n. The panel rejected TID’s interpretation of § 695n. The panel held that with respect to the textual argument made by TID, the language of § 695n, whether considered in isolation or in the context of the rest of 4 TULELAKE IRRIGATION DISTRICT V. USFWS the Kuchel Act, was unambiguous. The panel held that it did not, therefore, need to proceed to step two of the Chevron analysis. The panel concluded that the Kuchel Act required the Service to regulate the pattern of lease land agriculture in the refuges to ensure consistency with proper waterfowl management. Second, TIL argued that agriculture was a “purpose,” not a “use,” of the Tule Lake and Lower Klamath Refuges, and that a compatibility determination by the Service was therefore not authorized under the Refuge Act. The panel rejected TID’s argument that agriculture was a coequal purpose rather than a “use” within the meaning of the Refuge Act. With respect to the textual argument made by TID, the language of § 695l was unambiguous, making it unnecessary to proceed to step two of the Chevron analysis. The panel held that the Refuge Act permitted agricultural “use” within the Klamath Refuge Complex only when the Service determines that it is “compatible with the major purposes” for which the area was established. The panel held that under both the Kuchel and Refuge Acts the Service was required to ensure that agricultural use of leased land in the Lower Klamath and Tule Lake Refuges was “consistent” with (under the Kuchel Act) and “compatible” with (under the Refuge Act) “proper wildlife management.” The panel further held that the regulation in the EIS/CCP of agricultural uses of lease land was a proper exercise of the Service’s authority under the Kuchel and Refuge Acts. TULELAKE IRRIGATION DISTRICT V. USFWS 5
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.