O’Neil v. Steele

The federal district court for the District of Montana rejected a pro se plaintiff’s claim that the U.S. Forest Service failed to properly consider the “albedo effect” in its environmental review of a management plan for Flathead National Forest. The court described the albedo effect as referring “to the dynamic process by which objects ‘reflect light back into space’” and said that “some argue efforts to ‘increase the albedo of the earth’s surface,’ by fostering landscapes that reflect light, rather than absorb it, will help alleviate the warming effects of climate change.” The court continued by noting that such efforts might include managed deforestation to increase “‘land cover such as fields or bare ground,’ which absorb much less sunlight than ‘tree leaves.’” The court found that the U.S. had directly responded to the plaintiff’s comments on the albedo effect, had thoroughly considered the plan’s impacts on climate change, and (partially in response to the plaintiff’s concerns) had even generated alternatives that increased timber harvests. The court also denied the plaintiff’s motion to amend his complaint.