a discrete agency action that it is required to take,” 542 U.S. at 64, 124 S.Ct. 2373 (emphases in original). The BLM maintains that the duty to inventory wilderness values imposed on the BLM by 43 U.S.C. § 1711 is not such a discrete duty. ONDA challenges the EIS, under 5 U.S.C. § 706(2)(A), as “arbitrary, capricious, an abuse of discretion, or otherwise not in accordance with law,” not under 5 U.S.C. § 706(1), as “agency action unlawfully withheld or unreasonably delayed.” There is no doubt that it may do so. Once an EIS’s analysis has been solidified in a ROD, an agency has taken final agency action, reviewable under § 706(2)(A). See 40 C.F.R. § 1505.2(a) (the ROD “[s]tate[s] what the decision was”); see also Laub v. U.S. Dep’t of the Interior, 342 F.3d 1080, 1087-91 (9th Cir.2003) (<HOLDING>); Or. Natural Res. Council v. Harrell, 52 F.3d
holding that it appears wellestablished that a final eis or the rod issued thereon constitute the final agency action for purposes of the apa and collecting cases holding it well settled that a final eis or the record of decision issued thereon constitute  final agency action  holding that the designation of the rod as final agency action under the apa is generally recognized holding a rod to be final agency action holding that the rod and eis for a program were final agency action