As a result of lawsuits filed against the BLM's record of Decision (ROD), the U.S. District Court issued orders, dated February 25, 2005, and April 5, 2005, that required the BLM to prepare a Supplemental Environmental Impact Statement (SEIS) to evaluate a phased development alternative for coal bed natural gas (CBNG) production. The U.S. District Court also issued an order, dated February 25, 2005, advising the BLM to include the proposed Tongue River Railroad in the cumulative impact analysis and analyze the effectiveness of water well mitigation agreements
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