In late 2013, the Obama Administration, as requested by the wind energy industry, announced that it would allow certain wind energy companies to kill or injure bald and golden eagles for up to 30 years without penalty. The Department of the Interior developed a rule modifying the existing 5-year "eagle-take" rule with a 30-year rule allowing wind energy companies to obtain 30-year permits to kills golden and bald eagles without prosecution by the federal government. The court invalidated the rule, citing a lack of compliance with the National Environmental Policy Act. The court determined that the U.S. Fish and Wildlife Service (FWS) had failed to show an adequate basis in the record for deciding not to prepare an environmental impact statement (as required by NEPA) or an environmental assessment before adopting the 30-year rule. The court invalidated the rule and remanded to the FWS "for further consideration." Shearwater, et al. v. Ashe, et al., No. 14CV02830LHK, 2015 U.S. Dist. LEXIS 106277 (N.D. Cal. Aug. 11, 2015).