Pit River Tribe v. BLM, No. 13-16961 (9th Cir. 2015)
Annotate this CasePit River appealed the district court's order granting judgment on the pleadings of its action challenging BLM's continuation of geothermal leases. The court concluded that the district court incorrectly treated Pit River’s claims as arising under only section 1005(a) of the Geothermal Steam Act, 30 U.S.C. 1005(a). In this case, BLM’s 1998 decision to continue the 26 unproven leases in the Glass Mountain unit under section 1005(a) was issued simultaneously with its decision to reverse and vacate its earlier decision to extend those leases on a lease-by-lease basis under section 1005(g). Thus, Pit River’s challenge to the decisions implicates both section 1005(a) and section 1005(g). The court further concluded that Pit River's claims fall within the zone of interests under section 1005(g) and Pit River has stated a claim under section 1005(g) where BLM must conduct environmental, historical and cultural review under relevant federal law before granting lease extensions under section 1005(g). The district court did not consider the merits of Pit River’s Geothermal Steam Act claims, and determining whether BLM violated provisions of the Geothermal Steam Act will require careful analysis. Therefore, the court declined to rule on the merits of this issue and remanded for further proceedings. The court reversed the district court’s order granting judgment on the pleadings.
Court Description: Environmental Law. The panel reversed the district court’s order granting judgment on the pleadings in an action brought by environmental organizations challenging the Bureau of Land Management’s continuation of 26 geothermal leases in northeastern California’s Medicine Lake Highlands. The panel held that the district court incorrectly treated the environmental organizations’ claims as arising under only § 1005(a) of the Geothermal Steam Act. BLM’s 1998 decision to continue the 26 unproven leases in the Glass Mountain Unit under § 1005(a) was issued simultaneously with its decision to reverse and vacate its earlier decision to extend those leases on a lease-by-lease basis under § 1005(g). The panel held, thus, that the environmental organizations’ challenge to BLM’s decisions issued on May 18, 1998 implicated both § 1005(a) and § 1005(g). PIT RIVER TRIBE V. BLM 3 Because BLM must conduct environmental, historical, and cultural review under the National Environmental Policy Act and the National Historic Preservation Act before granting lease extensions under § 1005(g), the panel held that the environmental organizations’ claim fell within § 1005(g)’s zone-of-interests, and the organizations had stated a claim under § 1005(g). The panel declined the environmental organizations’ invitation to rule on the merits of its Geothermal Steam Act claims, and remanded for further proceedings.
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