BKS lawyers and their co-counsel achieved a significant victory in the Ninth Circuit on behalf of Central Valley Project contractors. The Court upheld the conversion of the contracts under the Water Infrastructure Improvements for the Nation (WIIN) Act. Because the WIIN Act required Reclamation to convert qualifying water service contracts upon request, the Court found Reclamation had no discretion to modify contractual terms to address environmental concerns. Consequently, the conversion process did not trigger review under NEPA or consultation under the Endangered Species Act. The published decision provides important precedent regarding federal environmental review obligations in the context of a statute that constrains the agency’s authority.