Sierra Club, Iowa Chapter v. LaHood

The court granted defendants’ motion for summary judgment, finding that the agencies had not acted arbitrarily and capriciously in approving an 8.5-mile highway extension southwest of Cedar Rapids, Iowa.  The court was not persuaded by plaintiffs’ arguments that under the Eighth Circuit’s decision in Mid States Coalition for Progress v. Surface Transportation Board, 345 F.3d 520 (8th Cir. 2003), climate change must be considered in an environmental review under NEPA.  Finding that Mid States Coalition for Progress required consideration of impacts on air quality more generally—not climate change specifically—the district court ruled that “there is no requirement that climate change be analyzed, particularly given the speculative nature of such an effect.