A federal judge has temporarily blocked livestock grazing across 22,000 acres of public land in Oregon, siding with environmental advocates who argue the area is critical for sage grouse research and habitat conservation.
The preliminary injunction, issued in response to a lawsuit by the Oregon Natural Desert Association (ONDA), halts the Bureau of Land Management (BLM) from allowing grazing on 13 designated Research Natural Areas (RNAs), which were initially closed to grazing in a 2015 conservation plan to protect sagebrush ecosystems vital to the greater sage-grouse.
ONDA claims the BLM’s January 2025 decision to scale back protections in those areas undermines long-standing scientific efforts, and the court agreed that the group is likely to succeed in proving the agency acted unlawfully. The order will remain in place while the lawsuit proceeds.
Background
In 2015, BLM designated 15 key RNAs across nearly 22,000 acres in Oregon as off-limits to livestock grazing under a conservation plan to protect greater sage-grouse habitat. These RNAs were intended to serve as undisturbed control sites for scientific study on the effects of grazing on sagebrush ecosystems. Although the plan barred new grazing permits, only two RNAs had ceased grazing by that year, leaving 13 still in use, according to the suit.
In 2019, ONDA sued the BLM over delays in implementing the grazing closures. A federal court agreed in 2022 that the agency had unreasonably delayed and ordered the closures to be enforced without further delay. The court later approved a stipulated remedy in 2023, outlining how BLM would phase out grazing in those areas, resulting in the closure of the 13 key RNAs over the next two years.
The conflict reignited in 2025 when BLM approved a new amendment to the 2015 conservation plan that dramatically reduced protected acreage to just 3,700 acres and cut the number of ungrazed RNAs from 13 to eight.
ONDA alleges these changes violate the Federal Land Policy and Management Act (FLPMA) and the National Environmental Policy Act (NEPA). The group claims the agency broke its commitments by weakening protections and failing to justify or explain the reversal.
Court ruling on likelihood
In evaluating the lawsuit against the BLM, U.S District Judge Michael Simon focused on whether the agency provided sufficient justification for its decision to scale back protections on sage grouse research areas.
ONDA argued that the agency’s policy reversal was arbitrary and capricious under the Administrative Procedure Act (APA), pointing to precedent from Organized Village of Kake v. USDA. In that case, the 9th Circuit Court of Appeals faulted an agency for reversing course without explaining why an action previously deemed harmful was suddenly acceptable. Similarly, ONDA argued that BLM had once deemed the original 13 RNAs the “minimum” necessary for reliable research, but later cut those areas by 83% without adequate justification.
BLM countered that its decision was informed by new scientific data gathered between 2015 and 2025. While the court acknowledged that agencies may change policies in light of new information, it found BLM’s explanation lacking. Simon said the agency failed to address why the reduced acreage would still meet research goals, especially when its previous findings stated the original RNA configuration was the minimum required.
Ultimately, the court found that ONDA is likely to succeed on its claims under FLPMA and NEPA, grounded in the APA’s requirement that agency decisions be reasoned and consistent. “BLM does not explain why this reduced amount of land will still provide statistically valuable baselines,” Simon wrote, concluding that the 2025 plan rests on “factual findings contradicting” earlier agency determinations.
Irreparable harm
The court found that ONDA sufficiently demonstrated irreparable harm to its interests in preserving ungrazed sagebrush ecosystems and supporting science-based land management. The court emphasized that ONDA members’ ability to view and study undisturbed sagebrush areas is a legally recognized injury. Since 2022, RNAs have remained ungrazed, giving ONDA members a rare opportunity to observe their natural recovery, the court said.
The court rejected BLM’s claims that grazing causes only minimal or recoverable effects, finding ONDA’s evidence of long-term ecological degradation—including soil erosion, altered vegetation and harm to sage-grouse habitat—more persuasive.
As for the impact on ranchers, the court acknowledged that a preliminary injunction may disrupt 2025 grazing plans and impose costs, such as the need to find alternative feed or reduce herd size.
One rancher, Joe Cahill, claimed potential losses of up to 30% of his ranch’s annual income. However, ONDA presented data showing Cahill Ranches recently used only about half of its authorized grazing allotment. The court concluded that while the injunction imposes a burden, it does not outweigh the demonstrated environmental harm or the public interest in compliance with science-based and lawful land management practices. — Charles Wallace, WLJ contributing editor
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