In joint comments submitted on Dec. 30, a coalition of nonprofits led by Public Employees for Environmental Responsibility, or PEER, said the agencies are failing to meet that mandate by attempting to replace the management plan with a workaround that is not subject to environmental review.
The groups contend that the proposal repeats the same flaw the court identified last year: relying on existing flight levels as a baseline without evaluating their effects on wildlife, park resources or visitor experience. In its ruling, the court said that approach improperly “enshrined the status quo” without ever examining its environmental consequences.