In 1994, the League Environmental Assistance Foundation (LEAF) petitioned the EPA to withdraw approval of the Alabama UIC program because did not regulate hydraulic fracturing associated with methane production. The EPA denied the petition in 1995 because, they contended, regulating hydraulic fracturing was not necessary given the definition of underground injection as used in the SDWA. The petition was taken to the Court of Appeals for the eleventh circuit, and they ruled against the EPA, arguing that there was no ambiguity in the SDWA’s mandate for the EPA’s regulatory action. They ruled that hydraulic fracturing should be regulated under federal law. This resulted in the EPA withdrawing approval of the Alabama UIC program in 1999, and Alabama’s