JOHN O. MARSH, JR., SECRETARY OF THE ARMY, ET AL., PETITIONERS V. OREGON NATURAL RESOURCES COUNCIL, ET AL. No. 87-1704 In the Supreme Court of the United States October Term, 1988 On Writ of Certiorari to the United States Court of Appeals for the Ninth Circuit Reply Brief for the Petitioners Respondents attempt to defend the court of appeals' decision on the same basis that they opposed certiorari -- by directing this Court's attention to issues that are not in this case, by arguing that the court of appeals did not really mean what it said, and by positing other rationales for the court's result. Respondents (and their amici) are understandably reluctant to defend the court of appeals' actual reasoning, but their alternative arguments are equally unsatisfactory and are insufficient to support the court of appeals' reversal of the district court's decision in this case. 1. Respondents devote the initial portion of their brief (at 1-8) largely to criticism of the substantive merits of the Elk Creek Project. The issue in this case, however, is not whether Congress should have approved the project; it is whether the Army Corps of Engineers prepared an adequate environmental impact statement. /1/ Respondents' recitation of the Elk Creek Project's adverse environmental consequences itself provides a telling indication of the adequacy of the Elk Creek Supplemental Statement: respondents rely almost entirely on that document in describing the project's adverse effects. See Resp. Br. 1, 2, 3, 4, 5, 6, 7, 8. As respondents acknowledge, the Elk Creek Supplemental Statement specifically informed the decisionmaker that (among other matters) "(t)he project might enhance fish to some degree, but at best will only compensate for the dam's adverse impacts on other existing fish and wildlife resources" and that "(t)he Elk Creek Dam would displace and, without mitigation, eliminate wildlife populations dependent on the habitat that would be flooded" (Resp. Br. 1, 2 (citing Elk Creek Supplemental Statement 5-6, 38, 46, 69-70)). As respondents further acknowledge, the Elk Creek Supplemental Statement, in its comment section, alerted the decisionmaker to additional concerns of interested parties and the Corps' responses. See Resp. Br. 3, 4, 5, 6, 7, 8. In short, respondents' extensive reliance on the Elk Creek Supplemental Statement's discussion of adverse environmental impact pointedly illustrates that the document fulfilled its objective of assuring that the Corps considered the environmental effects of the proposal and informed the public that the agency has considered environmental concerns in the decisionmaking process. See Baltimore Gas & Elec. Co. v. Natural Resources Defense Council, Inc., 462 U.S. 87, 97 (1983). See also Pet. Br. 14. /2/ 2. As the government's opening brief explained (at 15-26), the court of appeals erred in concluding that NEPA requires environmental impact statements to include a complete plan for mitigating environmental damage. Respondents make no attempt to defend such a requirement. Instead, they ask this Court to regard the lower court's explicit pronouncements as no more than "mere dictum" (Resp. Br. 12 n.5). Respondents struggle to recharacterize and downplay the crucial passages of the court of appeals' decision in order to sidestep the issues that prompted the government to seek this Court's review. But that response was unpersuasive at the petition stage, and it is equally unpersuasive now. /3/ The court of appeals unequivocally stated that environmental impact statements "must include a discussion of measures to mitigate adverse environmental impacts" (Pet. App. 5a) and -- in respondents' words -- that "significant measures must be undertaken to mitigate the adverse effects of a proposed action" (Resp. Br. 12 n.5). The court then imposed that same regimen -- using even broader language -- in Methow Valley Citizens Council v. Regional Forester, 833, F.2d 810, 819 (9th Cir. 1987), cert. granted, No. 87-1703 (June 27, 1988). Thus, respondents' argument that the court of appeals "did not require mitigation (Resp. Br. 12 (emphasis in original)) is flatly contradicted by the court's own words and actions. Similarly, the court of appeals unequivocally required a "complete mitigation plan" (Pet. App. 7a), including an "analysis of the mitigation measures" and an "estimation of how effective the measures will be" (id. at 6a-7a), and imposed those same requirements in Methow Valley Citizens Council, 833 F.2d at 820. Respondents' argument that the court did not require "'demonstrably effective plans for mitigating environmental harm'" (Resp. Br. 12 (quoting Pet. Br. 14)) thus fails as well. Respondents' attempt to rewrite the court of appeals' decision should be accepted for what it is -- an admission of the indefensibility of the court's reasoning and result. Respondents have effectively confessed that NEPA does not require a "complete mitigation plan" (Pet. App. 7a). They are left defending the court of appeals' decision on an alternative -- and far narrower -- ground; namely, that in this particular case, the "discussion of mitigation failed to provide the decisionmaker with the information necessary to make an informed decision" (Resp. Br. 12). But even that argument is unpersuasive. /4/ As we explained in our opening brief (at 19), no one -- including the government -- has questioned that a federal agency can and should consider mitigation opportunities when assessing the environmental consequences of a proposed action. The crucial issue here is the role that mitigation considerations play in the agency's environmental review. We submit that NEPA (and the CEQ's implementing regulations) contemplate that the government will discuss mitigation in a manner that aids reasoned decisionmaking and, more specifically, that an agency "has broad discretion to determine the form and scope of the mitigation discussion in light of the particular circumstances, subject only to the requirements that the environmental review as a whole satisfies NEPA's specific requirements and that the resulting decision is not arbitrary or capricious" (ibid.). See Baltimore Gas & Elec. Co., 462 U.S. at 97-98, 105-106. Respondents acknowledge that "the choice of how, or even whether, to mitigate is solely the agency's" (Resp. Br. 16), and they can point to nothing in NEPA or the CEQ regulations that prohibits the government from tailoring the scope of the mitigation discussion to the characteristics of the particular project. Instead, as we explained in our opening brief (at 22 n.14), NEPA requires a "detailed" statement (42 U.S.C. 4332(2)(C)), but it does not require that every subsidiary issue in an environmental impact statement must be discussed in exhaustive detail. Likewise, the CEQ regulations require a discussion of mitigation at certain points in the preparation of the environmental impact statement (40 C.F.R. 1502.14, 1502.16), but they leave the agency with responsibility to determine the scope of that discussion in light of the CEQ's direction that they "prepar(e) analytic rather than encyclopedic * * * statements," "discuss() only briefly issues other than significant ones," and "emphasiz(e) the portions of the * * * statement that are useful to decisionmakers and the public" (40 C.F.R. 1500.4). Respondents' contention that the Elk Creek Supplemental Statement's mitigation discussion is inadequate rests wholly on their repeated assertions that the Corps "represented that there would be no adverse environmental consequences for wildlife" (Resp. Br. 13) and "relie(d) on mitigation to compensate for the environmental consequences of (the) proposed action" (id. at 17; see also id. at 13, 14, 16-17). But those statements incorrectly portray the Elk Creek Supplemental Statement's actual content and the Corps' actual decision. The Elk Creek Supplemental Statement did not promise that a mitigation plan would eliminate the project's adverse impacts on wildlife. Instead, the Supplemental Statement identified the wildlife species that would be affected, and further noted that a wildlife mitigation plan "would reduce" the impacts upon two specific species: deer and quail. /5/ As the Record of Decision indicates (Pet. App. 57a), the Corps ultimately elected to develop a mitigation plan, but its decision to go forward with the project was not contingent on either the adoption or the sucess of that plan. As the Corps later explained, it decided to proceed with the project based on an environmental impact statement that "assumed the maximum level of adverse effects to wildlife" (id. at 61a), and it elected to implement a $350,000 wildlife mitigation plan as a supplemental measure to "lessen the extent of wildlife impacts" (ibid.). The Corps, in short, complied with not only the letter but the spirit of NEPA by incorporating environmental mitigation measures as a prudent and responsible course of action, even though they were not necessary to render the project environmentally acceptable. This is precisely the type of agency attitude that NEPA was intended to encourage. /6/ Respondents' fact-based challenge to the Elk Creek Supplemental Statement's discussion of wildlife mitigation is, in sum, unpersuasive. The discussion was appropriately tailored in relation to the severity of the environmental effects at issue and the likely importance that mitigation reasonably could be expected to play in the decision under consideration. See Metropolitan Edison Co. v. People Against Nuclear Energy, 460 U.S. 766, 776 (1983) ("The scope of the agency's inquiries must remain manageable if NEPA's goal of 'insur(ing) a fully informed and well-considered decision'" * * * is to be accomplished.") (citation omitted). Moreover, respondents' position would penalize the Corps for taking the environmentally responsible action of electing to develop wildlife mitigation measures over and above what was necessary to make the project environmentally acceptable. 3. The government's opening brief explained (at 26-35) that the court of appeals also erred in nullifying the CEQ's carefully deliberated regulatory revision of the so-called "worst case" regulation. Here, again, respondents attempt to avoid the question that prompted the government to seek this Court's review. /7/ To the extent that respondents attempt to defend the court of appeals' actual reasoning, their arguments are unpersuasive. The court of appeals held that the Elk Creek Supplemental Statement revealed uncertainty concerning Elk Creek's contribution to the total turbidity of the Rogue River and that the Corps therefore must conduct a "worst cast" analysis of that matter, even though the regulation that specified that methodology has since been rescinded and replaced by a regulation setting forth an alternative methodology (Pet. App. 14a). The court specifically stated that the worst case regulation was a "codification of prior NEPA case law" and that "the rules embodied in that regulation remain in effect even though the regulation was rescinded" (id. at 14a n.8). The court also specified that on remand the Corps must conduct a worst case analysis or conduct further research (id. at 15a). In short, the court nullified the CEQ's regulatory amendment and required the Corps to comply with the rescinded regulation. /8/ Respondents assert that NEPA itself requires agencies to "include 'worst' as well as 'best' case scenarios" in projecting potential environmental consequences (Resp. Br. 19-20) (footnote omitted)). NEPA, however, nowhere speaks in terms of "best" and "worst" cases; instead, it requires the agency to discuss "the environmental impact of the proposed action" (42 U.S.C. 4332(2)(C)(i)). The lower courts have recognized that an agency's discussion of the proposed action's environmental impact should include an acknowledgement of gaps in scientific information and reasonable forecasting of probable environmental consequences. See Pet. Br. 31-33. But there is no statutory requirement -- or logical justification -- for requiring an agency to discuss the "best" and "worst" scenarios. The CEQ has rightly concluded that polar forecasts -- whether based on the best or the worst case -- are not an effective method for evaluating environmental impacts. The methodology inevitably leads to "pure conjecture" that "is not useful to either the decisionmaker or the public" (50 Fed. Reg. 32,236 (1985) (emphasis in original)). /9/ Respondent's related argument -- that the CEQ's amended regulationon is inadequate because it requires projection of future environmental effects be supported by "'credible scientific evidence'" (Resp. Br. 22 n.14) -- is untenable and, if accepted, would actually reduce the usefulness of environmental impact statements. Respondents' desire for analysis based upon nonscientific conjecture cannot be squared with NEPA's goal of improved governmental decisionmaking. As our opening brief explains (at 33), such inquiries are wastful and time-consuming, they have no logical limits, and they fail to provide the decisionmaker and the public with useful information. /10/ 4. As the government's opening brief explained (at 35-44), the court of appeals also erred in reversing the district court's determination that the Corps adequately considered new information concerning environmental effects that was presented after the completion of the Elk Creek Supplemental Statement. Respondents fail to offer persuasive support for either the court of appeals' standard of review or the court's ultimate decision. The parties agree (Pet. Br. 36 n.30; Resp. Br. 30) that the agency must prepare a supplemental environmental impact statement if the agency determines that the new information has "significant" relevance or bearing on the proposed action or its effects. See 33 C.F.R. 230.11(b) (Corps NEPA regulations); 40 C.F.R. 1502.9(c)(1)(ii) (CEQ regulations). /11/ The agency's determination of this matter proceeds upon the so-called "rule of reason" -- a phrase that expresses the agency's responsibility to assess the new information pragmatically in light of its value in the decisionmaking process. See, e.g., Cuomo v. United States Nuclear Regulatory Comm'n, 772 F.2d 972, 974 (D.C. Cir. 1985); Friends of the River v. FERC, 720 F.2d 93, 109 (D.C. 1983). A court's review of the agency's decision, however, is governed by the Administrative Procedure Act (APA), 5 U.S.C. 701 et seq. A reviewing court may not set aside an agency's decision to forgo preparation or supplementation of an environmental impact statement unless the action is "arbitrary, capricious, an abuse of discretion, or otherwise not in accordance with law" (5 U.S.C. 706(2)(A)). See, e.g., Wisconsin v. Weinberger, 745 F.2d 412, 418 (7th Cir. 1984). There is no statutory basis for the Ninth Circuit's less deferential "reasonableness" standard. Indeed, respondents themselves offer only equivocal support for the Ninth Circuit's test. /12/ Respondents are fundamentally mistaken in contending (at 29) that an agency's evaluation of whether new information is significant is not entitled to deference because it "does not * * * involve a determination requiring 'a high level of technical expertise,' nor is it one which must be 'left to the informed discretion of the responsible federal agencies'" (quoting Pet. Br. 36, which in turn quotes Kleepe v. Sierra Club, 427 U.S. 390, 412 (1976)). The Corps' decision whether to supplement further the Elk Creek Supplemental Statement turned upon its technical evaluation of new scientific information. "When examining this kind of scientific determination, as opposed to simple findings of fact, a reviewing court must generally be at its most deferential." Baltimore Gas & Elec. Co., 462 U.S. at 103. Indeed, respondents' lengthy recitation of flawed and incomplete scientific assertions bears this out. Respondents first contend (Br. 35-45) that the ODFW Report -- a Corps-funded state agency study that addressed the effects of the Lost Creek Dam on fisheries resources -- provided significant new environmental information. But as the district court noted, respondents actually sought relief based on the Cramer Memorandum, an unofficial memorandum by two ODFW biologists that expressed concern, based on the draft ODFW Report, that the Elk Creek Dam could adversely affect fisheries. See Pet. Br. 9 n.4. The Cramer Memorandum (which is reproduced at Pet. Br. Add. 3a-6a) is the only document that extrapolates the ODFW Report to Elk Creek. In addition, it is the Cramer Memorandum -- and not the ODFW Report -- that mentions turbidity and anglers' concerns. Respondents made no effort to put this information before the Corps until after they filed suit. They first produced the Cramer Memorandum -- an unofficial internal document -- in their brief in support of a motion for a temporary restraining order. See Pet. Br. 9 n.4. They nevertheless criticize the Corps for failing to respond to the Cramer Memorandum and its extrapolation of the ODFW Report "until three months after the commencement of this case" (Resp. Br. 38). Furthermore, they now attempt to establish their claim that the Corps neglected to consider new information by relying on scientific assertions contained in trial depositions and affidavits (id. at 36, 37, 39, 40, 42, 43, 44, 45) that were prepared after this suit was filed. In short, respondents have sued the Corps for failing to address information that was not made available to the agency until trial. As this Court explained in Vermont Yankee Nuclear Power Corp. v. Natural Resources Defense Council, Inc., 435 U.S. 519, 553-555 (1978), NEPA litigants are not entitled to sue first and create the cause of action later. /13/ In any event, the information that respondents cite is not sufficiently meaningful or reliable to justify the preparation of another supplemental environmental impact statement. As our opening brief explained (at 39-42), the Cramer Memorandum is, on its face, a brief, cursory, and conclusory statement of dubious scientific worth. It relies upon, and extrapolates from, the author's own ODFW Report, which has been seriously criticized by both the Corps and independent experts. /14/ As the Corps' Elk Creek SIR explained, the ODFW Report's mathematical model on fry survival was questionable and the Corps' own experiments indicated that operation of the multiport intake tower could ameliorate temperature impacts (Pet. Br. Add. 9a-10a). /15/ Furthermore, neither the Cramer Memorandum nor the ODFW Report established a link between the construction of Lost Creek Dam and an outbreak of epizootics (Pet. Br. Add. 10a-11a). /16/ In sum, respondents have failed to show that the Corps acted arbitrarily (or even unreasonably) in concluding that the Cramer Memorandum and the ODFW Report did not reveal significant new information. The same is true with respect to the SCS Report. /17/ Respondents contend that the government "conveniently ignore(s) the Corps' own use of soil characteristics to predict turbidity" (Resp. Br. 47). But as respondents themselves recognize (id. at 4), the Corps developed its turbidity projections primarily through computer simulation using the Corps' "WESTEX" model. In building a data base for the WESTEX simulation, the Corps took water samples and measured their actual sediment content; it did not rely on soil maps to determine turbidity. See Elk Creek Supplemental Statement 22, 33-34; 1974 Water Quality Report 41-47, Figs. 8-9. The Corps was accordingly justified in concluding that the SCS Report's soil maps did not provide significant new information. 5. At bottom, respondents fail to recognize that NEPA has important but limited objectives: it is designed to ensure that agencies consider the environmental effects of their actions and inform the public that they have taken environmental concerns into account in the decisionmaking process. Baltimore Gas & Elec. Co., 462 U.S. at 97. As this Court has stated (id. at 100): Congress did not enact NEPA, of course, so that an agency would contemplate the environmental impact of an action as an abstract exercise. Rather, Congress intended that the "hard look" be incorporated as part of the agency's process of deciding whether to pursue a particular federal action. The Corps took that "hard look" here, and that is all that NEPA requires. For the foregoing reasons and the reasons stated in our opening brief, the judgment of the court of appeals should be reversed with instructions to remand the case to the agency for further proceedings. Respectfully submitted. CHARLES FRIED Solicitor General DECEMBER 1988 /1/ Notably, respondents base much of their criticism on a GAO report (A.R. Doc. 35) that addressed the Corps' cost-benefit analysis for the project. But Congress did not find cause in the GAO's report (which, at the requestors' instruction, was not submitted to the Corps for pre-publication comment (id. at iv)) to half funding. And of special relevance here, the GAO report specifically stated that "GAO is not questioning the fish and wildlife benefits other than those related to irrigation" (id. at iii) -- a component that is no longer a part of the Elk Creek Project. /2/ Respondents take some liberties in characterizing the record. For example, they contend that the Elk Creek Dam would "increase turbidity downstream in the Rogue River, depressing salmon and steelhead populations" (Resp. Br. 2 (citing Elk Creek Supplemental Statement 46)). No such statement appears at the cited page. Instead, the Statement indicates (at 37) that "(n)o major adverse effect on fish production in the Rogue River is expected as a result of the changes in the turbidity regime as a result of the Elk Creek project." As another example, respondents contend that "turbidity peaks and their duration" are "not disclosed by the Corps" (Resp. Br. 5). In fact, the 1974 Water Quality Report shows in graphic and tabular form the turbidity peaks and durations (as well as changes in flow and temperature) with no dams, with Lost Creek, with Elk Creek, and with both dams operating together for four different water years under three different operational modes (A.R. Doc. 4, charts 76-91, tables 18-45, 49-84). The Corps used average daily turbidity figures, rather than hourly figures, because short-term turbidity -- except at levels far beyond what would occur here -- has little effect on fish survival (Elk Creek Supplemental Statement 37). /3/ The government specifically petitioned this Court to decide whether NEPA "requires federal agencies to include in each environmental impact statement * * * a fully developed plan to mitigate environmental harm" (Pet. I). As the government' s petitioner explained (at 9-14), the question warrants the Court's attention because the court of appeals' answer establishes a rule of law that is fundamentally incorrect (which respondents apparently concede) and establishes a precedent that, as a practical matter, would seriously frustrate or impede a wide range of federal and federally permitted projects. In short, this Court granted review on the question whether NEPA requires that environmental impact statements must include a complete mitigation plan, and it is that question that respondents should address. /4/ The court of appeals found the Supplemental Statement's mitigation discussion wanting only because that court based its evaluation on the novel and mistaken premise that environmental impact statements must provide a "complete mitigation plan" (Pet. App. 7a). See Pet. App. 5a-6a ("Here, the mitigation plan for wildlife is not yet fully developed. * * * We fail to see how mitigation measures can be properly analyzed and their effectiveness explained when they have yet to be developed."). The court presumably would have found the mitigation discussion adequate under any lesser standard. Indeed, even the district court, which erroneously stated that "NEPA requires that the Corps * * * mitigate (adverse environmental) effects to the greatest extent possible" (Pet. App. 42a), expressly rejected respondents' argument that the Elk Creek Supplemental Statement gave insufficient attention to mitigation (Pet. App. 41a-42a). If we are correct in our contentions that the court of appeals erred in respect to the agency's substantive and procedural requirements regarding mitigation and worst case analysis, and erred as well in respect to the duty to consider what respondents characterize as "significant" new information, then on remand the agency should be required to do no more than comply with the court of appeals' order that the agency provide further elaboration on the subject of cumulative impacts -- an order from which we did not seek review in this Court. See Pet. Br. 15 n.6, 45 n.5. Respondents insist that we overread the court of appeals' opinion on the first two matters. We do not think so, but if the court of appeals may be understood as intending no novel and onerous obligations in respect to mitigation and worst case analysis, then there is no basis for further proceedings in the court of appeals on those matters since we have clearly complied with the usual NEPA requirements, as we have shown in our opening brief and here. And if we read the court of appeals correctly, and our challenge to that court's view of the law is found by this Court to be correct, then there also appears no occasion for further proceedings in the court of appeals. /5/ The Supplemental Statement explained that construction of the Elk Creek REservoir would inundate 1,290 acres of wildlife habitat and would adversely affect resident mammals and game birds (id. at 26-27, 38). It stated (at 26) that approximately 50 deer and 17 elk had been observed in the project area. It also identified (at 26-27) other wildlife that could be present in the project area on a transient or permanent basis -- including possibly 2 mountain lions, 12 black bear, 10 grey foxes, 20 coyote, 6 bobcat, 35 raccoon, 20 skunks, 6 mink, 6 river otter, 2 weasels, and 125 quail, as well as other bird populations. It further noted (at 27) that no threatened or endangered species was found to exist in the project area. The Supplemental Statement estimated (at 26) that the project would ultimately affect perhaps 100 deer and a lesser number of elk, and respondents' own wildlife expert concurred in this assessment, estimating that the inundation would decrease Jackson County's deer population -- which numbers more than 100,000 -- by approximately 50 animals, and would displace -- but not reduce -- the 60 elk that were believed to live part-time in the reservoir area. See Pet. Br. 24 n.16. The Elk Creek Supplemental Statement further indicated (at 38) that a mitigation plan "would reduce" the project's impact on deer and quail, but that "all the other species of mammals would experience population reductions." Thus, respondents are incorrect in contending that the Corps "represented that there would be no aderse environmental consequences for wildlife" (Resp. Br. 13). The Elk Creek Supplemental Statement indicated that the project would have adverse wildlife impacts, but -- as the quantitative estimates of respondents' own wildlife expert confirmed -- those impacts would be relatively small. /6/ Respondents' argument that the Corps "relied" on the institution of a mitigation plan to conclude that the project is environmentally acceptable is not only unsupported by the Record of Decision, it is also quite far-fetched on the actual facts of this case. Respondents portray the project site as a veritable wildlife refuge. In fact, the project area (which previously had been in part privately owned ranch land) assumed much of its value as wildlife habitat after the Corps' "acquisition of the reservoir site and removal of all developments in the area" (Elk Creek Supplemental Statement 26). Even thereafter, the project area has supported relatively small populations of common wildlife (id. at 26-27). Thus, respondents' basic premise -- specifically, that the Corps' decision to go forward with the $97 million Elk Creek Project necessarily turned on the success of a mitigation plan directed primarily toward protecting some 125 quail and 50 deer (see note 5, supra) -- is unreasonable on its face. /7/ The government specifically petitioned this Court to decide whether NEPA "requires federal agencies to include in each environmental impact statement * * * * a 'worst case' analysis of potential environmental harm if relevant information is unavailable or too costly to obtain" (Pet. I). As the government's petition explained (at 15-18), the court's improper refusal to give effect to the CEQ's rescission of the worst case regulation would result in federal agencies' conducting wasteful and time-consuming inquires into potential environmental effects under a methodology that, as the CEQ has stated, produces "pure conjecture * * * lacking a credible scientific basis" (50 Fed. Reg. 32,236 (1985)). /8/ Amicus Center for Environmental Education (CEE) incorrectly contends that the court of appeals' requirement that the Corps conduct a worst case analysis "does not belong before this Court" (Amicus Br. 4). CEE notes (id. at 5-6) that the amended regulation is applicable to "all environmental impact statements for which a Notice of Intent * * * is published in the Federal Register on or after May 27, 1986" (40 C.F.R. 1502.22(c)). CEE then argues that "the document under review * * * was prepared well in advance of the effective date" and that "(b)y the terms of the amended regulation the original regulation applies" (CEE Amicus Br. 8). CEE neglects to note that the amended regulation further provides that "(f)or environmental impact statements in progress, agencies may choose to comply with the requirements of either the original or amended regulation" (40 C.F.R. 1502.22(c)). Thus, if an environmental impact statement was begun before May 27, 1986, but remains "in progress" after that date, the preparing agency, at its option, may employ either regulation. Here, the Elk Creek Statement remains "in progress" -- regardless of this Court's action -- because the Corps must revise and amend it to comply with the court of appeals' order (see Pet. Br. 45 n.45; see also note 4, supra). Thus, the amended regulation would give the Corps the option of evaluating uncertainty through the methodology set forth in the original or in the amended regulation. The court of appeals, however, denied the Corps that option and unequivocally commanded the agency to use the worst case methodology set forth in the original regulation. See Pet. App. 14a & n.8, 15a. The court of appeals thus nullified the effect of the amended regulation here, as well as in future cases, and the issue is properly before this Court. /9/ Respondents' sole support for the use of "best" and "worst" case scenarios is a 1981 CEQ commentary stating that the government should "present to the fullest extent possible the spectrum of consequences that may result from agency decisions" (46 Fed. Reg. 18,026, 18,032 (1981)). The CEQ withdrew that commentary in 1986. 51 Fed. Reg. 15,618. In any event, the commentary, which the CEQ provided to assist federal agencies in their compliance with the worst case regulation, provides scant support for respondents' statutory argument. Notably, respondents fail to grasp the point, set forth in our brief (at 31-33), that the worst case regulation was the CEQ's initial mechanism for achieving certain judicially recognized NEPA objectives -- namely, to assure that agencies engage in reasonable forecasting of future environmental effects and take into acount uncertainty -- and that the worst case methodology is not the only allowable mechanism for effecting those general goals. See Resp. Br. 21 n.13. Furthermore, respondents offer no standard to judge whether a supposed worst case is, in Shakespeare's words, "'at the worst'" (Pet. Br. 29 n.22). /10/ Respondents incorrectly assert that "the CEQ has not articulated any reason for its amendment (of the worst case regulation) other than the administrative convenience of the agencies" (Resp. Br. 24). The CEQ explained in detail that the amendment was necessary because the worst case methodology "is an unsatisfactory approach to the analysis of potential consequences in the face of missing information" (50 Fed. Reg. 32,236 (1985)), it is unworkable because of the "limitless nature of the inquiry established by this requirement" (ibid.), and it "lacks defensible rationale" (ibid.). Respondents' assertion that worst case analysis is a requirement" rather than "a 'methodology' or 'procedure'" (Resp. Br. 26) is a meaningless distinction. In any event, respondents err in asserting that "(t)here is no language in the opinion of the court of appeals imposing or suggesting a particular 'procedure' or 'methodology'" (id. at 27). The court of appeals clearly dictated that the Corps must follow the "rules embodied in the (original) regulation" when conducting a worst case analysis (Pet. App. 14a n.8). /11/ For the Court's convenience, we have reprinted relevant portions of these regulations in the Addendum to this brief. /12/ Respondents (Br. 29-32) and their amici (Environmental Defense Fund Amicus Br. 26) seem to suggest that an agency's environmental decisions should receive more exacting scrutiny than other agency decisions, but that argument finds no basis in law and simply reflects those parties' own priorities. Respondents ultimately concede (at 32) that the APA Section 706(2)(A) standard applies when a court reviews an agency's decision to forgo supplementation, but they contend (at 34) that only the Seventh Circuit employs the "arbitrary or capricious" component of that standard in this context. Respondents reach that result, however, by excluding those circuits (the D.C., Second, and Fourth Circuits) that have held that the "arbitrary or capricious" test is applicable in reviewing an agency's decision to forgo preparation of a statement in the first instance. See Pet. Br. 37. As the Seventh Circuit has explained (Wisconsin, 745 F.2d at 417), the same standard should apply in either case. Respondents' reliance (at 33) on Cuomo, supra, to support the Ninth Circuit's reasonableness standard is misplaced; as noted above, that case recognized that the agency applies a rule of reason test (772 F.2d at 974) and the case, in any event, could not overrule the D.C. Circuit's previous decision in Cabinet Mountains Wilderness/Scotchman's Peak Grizzly Bears v. Peterson, 685 F.2d 678, 681, 685 (D.C. Cir. 1982). Finally, respondents' suggestion that the court of appeals actually invalidated the Corps' decision because it was conducted "'without observance of procedure required by law'" (Resp. Br. 33, quoting 5 U.S.C. 706(2)(D)) finds no support in the court's opinion. /13/ Here, as in Vermont Yankee, "to characterize the action of the (agency) as 'arbitrary or capricious' in light of the facts then available to it * * * is to deprive those words of any meaning" (435 U.S. at 554). /14/ As Judge Wallace explained (Pet. App. 22a-23a), the experts were overwhelmingly critical of the ODFW Report's scientific validity. See Pet. Br. 41 n.40. Respondents note (Br. 38-39) that the experts and the Corps did not criticize every aspect of the Report, but that fact hardly validates a document that the experts described as containing considerable "statistical inaccuracies, over-extension of statistical methods, undue biological speculation" and that was "not likely to yield conclusive results" (Pet. App. 22a-23a). See Pet. Br. 41 n.40. /15/ Respondents' contention that Elk Creek SIR was "clearly framed only in terms of the significance of the mathematical model" (Resp. Br. 38 (emphasis in original)) is accordingly incorrect. Moreover, the Cramer Memorandum itself addressed fry survival primarily in terms of ODFW modeling attempts. Pet. Br. Add. 3a-4a. Respondents also fault the Elk Creek SIR for failing to discuss fry survival in terms of "genetic diversity" (Resp. Br. 39-40), but the Cramer Memorandum did not even raise that issue. /16/ Respondents contend -- citing the Cramer trial deposition -- that the tests used were not sufficiently sensitive; however, Cramer himself was unable to identify any more sensitive test. See Cramer Deposition 36-37. As for the Cramer Memorandum's passing concerns about angling and turbidity, the Elk Creek SIR adequately addressed them (Pet. Br. Add. 11a-12a). Respondents state that the "ODFW wanted to conduct studies to evaluate (angling) but the Corps, which funded the ODFW studies that led to the concern, refused to fund additional studies" (Resp. Br. 45 (citing Cramer Deposition 32)). Cramer himself admitted, however, that he had not propsed any such studies (Deposition 32), nor are we aware of any ODFW requests for additional funding to pursue this subject. /17/ Respondents did not inform the Corps that they intended to rely on the SCS Report as "new information" until the time of trial. As the trial transcript indicates (at 41), the government attorneys were not informed that the maps comprising the SCS Report would be used until they were marked for identification at trial. APPENDIX