Theodore Roosevelt Conservation Partnership v. Salazar
United States Court of Appeals for the District of Columbia Circuit
661 F.3d 66 (2011)
The Bureau of Land Management (BLM) (defendant) authorized expanded natural-gas development in the Pinedale Anticline Project Area in a 2008 Record of Decision that included mitigation measures like remote well monitoring, directional drilling from fewer well pads to reduce human presence, and a dedicated monitoring and mitigation fund. The Theodore Roosevelt Conservation Partnership (TRCP) (plaintiff) sued, arguing these measures would fail to prevent "unnecessary or undue" environmental degradation as the Federal Land Policy and Management Act (FLPMA) requires, and that a two-mile wildlife buffer was needed instead of the quarter-mile buffer BLM adopted.
Whether energy development on federal land violates the FLPMA's requirement to prevent unnecessary or undue environmental degradation, when the agency has adopted specific mitigation measures targeting the main sources of harm.