I look forward to seeing the BLM's Response. This will be critical in determing whether RSIC has demonstrated a likelihood of success on the merits (which is a high bar), particularly regarding whether the BLM acted reasonably and in good faith. Let's see.
I note the comment on page 21 “… the NHPA does not give the Indian tribes the power of consent to stop [the project]." This is true. The issue for the BLM is defending their actions. The issues for LAC are 1) project timing and 2) securing and building their social license to operate. If the RSIC genuinely just wanted to be properly consulted, you would think some form of ("without predjudice") compromise could be reached. Unfortunatley I don't think there is sufficient trust and goodwill for that to happen.
Onwards and upwards.