Pit River Tribe v. Bureau of Land Management, No. 17-15616 (9th Cir. 2019)
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The Ninth Circuit affirmed the district court's grant of summary judgment in favor of Pit River Tribe and environmental organizations in an action under the Geothermal Steam Act, against federal agencies responsible for administering twenty-six unproven geothermal leases located in California's Medicine Lake Highlands. Pit River alleged that the BLM's decision to continue the terms of the unproven leases for up to forty years violated the Act.
Determining that it had jurisdiction to hear this appeal, the panel held that the statutory meaning of 30 U.S.C. 1005(a) is clear and unambiguous: it only permits production-based continuations on a lease-by-lease basis, not on a unit-wide basis. In this case, BLM failed to meet its burden of providing a compelling reason for the panel to depart from the plain meaning of section 1005(a). Therefore, the panel rejected BLM's argument that section 1005(a) authorizes forty-year continuations on a unit-wide basis once a single lease in a unit is deemed productive.
Court Description: Geothermal Steam Act / Federal Leases. The panel affirmed the district court’s summary judgment in favor of Pit River Tribe and several environmental organizations in their action against federal agencies responsible for administering twenty-six unproven geothermal leases located in California’s Medicine Lake Highlands. Pit River alleged that the Bureau of Land Management’s decision to continue the terms of the unproven leases for up to forty years violated the Geothermal Steam Act (“GSA”). Section 1017 of the GSA authorizes the Secretary of the Interior to approve cooperative or unit plans to manage multiple geothermal leases as a unit, and the Secretary must review such unit plans every five years and eliminate any lease not reasonably necessary for unit operations under the plan. Section 1005(a) of the GSA provides that geothermal * The Honorable Roslyn O. Silver, United States District Judge for the District of Arizona, sitting by designation. PIT RIVER TRIBE V. BLM 3 leases on federal land have primary lease terms of ten years, and allows the leases to be continued for as long as geothermal steam is produced in commercial quantities. Section 1005(c) states that leases subject to “unit plans” may be extended even if not productive during the initial ten-year term under certain conditions. The panel held that the statutory meaning of 30 U.S.C. § 1005(a) was clear and unambiguous. The panel held that the provision permitted production-based forty-year continuations at the end of the primary term only on a lease- by-lease basis, not on a unit-wide basis. It was BLM’s burden to provide a compelling reason for the court to depart from the plain language of § 1005(a), and the panel concluded that it had not met that burden here.
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