The United States Court of Appeals for the Tenth Circuit recently upheld a Bureau of Land Management (BLM) decision allowing natural gas development in Wyoming's Powder River Basin. See Biodiversity Conservation Alliance v. Bureau of Land Management, Case No. 09-8011 (Jun. 18, 2010) (here; search using case number). Environmental groups challenged the decision, arguing that it violated the National Environmental Policy Act by failing to study in detail a decades-long phased-development plan proposed by the environmentalists.
The court: "The Bureau reasonably refused to give detailed study to a plan that would not meet the project's purposes." Interesting.