As U.S. companies continue to produce large quantities of oil and gas from unconventional formations, the need for new pipelines grows. By some estimates, more than 41,000 miles of new oil and gas pipelines will be built in the United States by 2035. ICF Consulting, North American Midstream Infrastructure Through 2035 (2018), https://www.ingaa.org/File.aspx?id=34658. The U.S. pipeline buildout has sparked a vociferous response from communities, environmental groups, and other citizen groups. The U.S. Federal Energy Regulatory Commission (FERC) approves the construction and siting of all interstate natural gas pipelines, and a growing number of legal challenges have borrowed from the full arsenal of environmental and public lands law to attempt to halt or slow down pipeline construction.