"Congress' inability or unwillingness to pass a law desired by the executive branch does not default authority to the executive branch to act independently, regardless of whether hydraulic fracturing is good or bad for the environment or the citizens of the United States," wrote Judge Skavdahl, whom Mr. Obama appointed to the bench in 2011.
http://www.washingtontimes.com/news/2016/jun/21/obama-administrations-fracking-rules-struck-down-f/
Guess what? Truth be told, that very same decision applies to the vast majority of Obama's executive orders, as well.