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Theodore Roosevelt Conservation Partnership v. Salazar

Citation: 40 ELR 20262
No. No. 08-1047, (D.D.C., 09/29/2010)

A district court dismissed a hunting and fishing organization's NEPA and FLPMA claims against the BLM challenging its approval of oil and gas operations in the Pinedale Anticline natural gas field in western Wyoming. Claims that the BLM violated FLPMA were dismissed because the record supports the agency's determination that "unnecessary or undue degradation" would not occur. Nor did the BLM violate NEPA. The agency's 2008 record of decision considered a reasonable range of alternatives, including a "no action" alternative, and it took a "hard look" at the operations' impacts on hunting and sage grouse as a whole. The record of decision also included a meaningful discussion on monitoring and mitigation.