Grunewald v. Jarvis, No. 13-5136 (D.C. Cir. 2015)Annotate this Case
After issuing an environmental impact statement (EIS), the National Park Service adopted a plan for the management of deer in Rock Creek National Park in Washington, D.C. The plan involved the killing of white-tailed deer. Objectors argued that the plan violated statutes governing management of the Park and was not adopted in compliance with the Administrative Procedure Act, and that the EIS did not meet the requirements of the National Environmental Policy Act. The district court rejected the claims on summary judgment. The D.C. Circuit affirmed. Noting that the Organic Act expressly provides that the Secretary of the Interior “may also provide in his discretion for the destruction of such animals and of such plant life as may be detrimental to the use of any said parks, monuments, or reservations,” so that the agency’s interpretation of its enabling act is reasonable. Given the impact of deer on plant life and vehicle collisions, the decision is not arbitrary. Finding no violation of NEPA, the court concluded that the EIS was not required to consider the psychological harm that some visitors may suffer from simply knowing that the intentional killing of deer happens at Rock Creek Park.