Plaintiffs challenged the adequacy of the agencies NEPA analysis for two oil and gas development project approvals. Claims related to the range of alternatives considered, analysis of cumulative climate change impacts, non-use of social cost of carbon protocol, analysis of impacts of hydraulic fracturing, analysis of impacts to big game, analysis of cumulative impacts to air quality and water quantity, and analysis of indirect greenhouse gas impacts.
Plaintiffs prevailed only on the indirect greenhouse gas claim. The court found that agencies (BLM and FS) had failed to quantify and analyze end-use ("downstream") greenhouse gas emissions for the projects.