On March 31, 2013, a magistrate judge with the U.S. District Court for the Northern District of California ruled in Center for Biological Diversity (CBD) v. Salazar that the U.S. Bureau of Land Management (BLM) violated the National Environmental Policy Act (NEPA) in issuing several oil and gas leases without first adequately analyzing the impacts of horizontal drilling and multistage hydraulic fracturing (fracking). Recognizing that land use planning for public lands has been outpaced by developments in drilling technology, the court held that additional NEPA review of fracking is required before BLM may issue leases that would constrain the agency’s ability to prevent surface disturbance on the leased land.