The Bureau of Land Management (BLM) (defendant) issued a Record of Decision (ROD) in 2000 to guide the management of substantial natural-gas resource development in the Pinedale Anticline Project Area (PAPA). In 2008, the BLM issued an ROD that authorized greater natural-gas development than the 2000 ROD and that implemented measures to mitigate environmental harm. These measures included actions designed to reduce human presence in the PAPA, including remote well monitoring and directional drilling from fewer well pads. These measures also included a monitoring and mitigation fund. The Theodore Roosevelt Conservation Partnership (TRCP) (plaintiff) sought relief in district court, claiming that the BLM’s 2008 ROD violated the Federal Land Policy and Management Act (FLPMA), 43 U.S.C. § 1701 et seq. TRCP asserted that the 2008 ROD’s mitigation measures would fail in violation of the FLPMA’s requirement that the BLM prevent “unnecessary or undue” degradation. TRCP also asserted the need for a two-mile buffer to protect wildlife, rather than the proposed quarter-mile buffer.