Noise pollution is also a concern and several studies conducted by Montana State University, California State University, University of Florida and others have cited possible negative behavioral changes in wildlife as the result of some ORV use. Some U.S. states have laws to reduce noise generated by off-road and non-highway vehicles. Washington is one example: "State law requires off-road and other non-highway vehicles to use specified noise-muffling devices (RCW 46.09.120(1) (e) maximum limits and test procedures). State agencies and local governments may adopt regulations governing the operation of non-highway vehicles on property, streets, or highways within their jurisdiction, provided they are not less stringent than state law (RCW 46.09.180 regulation by local political subdivisions)". Mojave desert controversy The U.S. Bureau of Land Management (BLM) supervises several large off-road vehicle areas in California's Mojave Desert. In 2009, U.S. District Judge Susan Illston ruled against the BLM's proposed designation of additional off-road use on designated open routes on public land. According to the ruling the BLM violated its own regulations when it designated approximately 5,000 miles of off-road vehicle routes in 2006. According to Judge Ilston the BLM's designation was "flawed because it does not contain a reasonable range of alternatives" to limit damage to sensitive habitat, as required under the National Environmental Policy Act. Illston found that the bureau had inadequately analyzed the route's impact on air quality, soils, plant communities and sensitive species such as the endangered Mojave fringe-toed lizard, pointing out that the United States Congress has declared that the California Desert and its resources are "extremely fragile, easily scarred, and slowly healed". The court also found that the BLM failed to follow route restrictions established in the agency's own conservation plan, resulting in the establishment of hundreds of illegal OHV routes during the previous three decades. The plan violated the BLM's own regulations, specifically the Federal Land Policy and Management Act of 1976 (FLPMA) and the National Environmental Policy Act of 1969 (NEPA). The ruling was considered a success for a coalition of conservation groups including the Friends of Juniper Flats, Community Off-road Vehicle Watch, California Native Plant Society, The Center for Biological Diversity, The Sierra Club, and The Wilderness Society who initiated the legal challenge in late 2006. Roadless area conservation Many U.S. national parks have discussed or enacted roadless rules and partial or total bans on ORVs. To accommodate enthusiasts, some parks like Big Cypress National