About Environmental Law

Welcome to the home page for Environmental Law, the nation’s oldest law review dedicated solely to environmental issues. Environmental Law is a premier legal forum for environmental and natural resources scholarship. Environmental Law is published quarterly by the students of Lewis & Clark Law School, 10015 S.W. Terwilliger Blvd., Portland, OR 97219, in the Spring, Summer, Fall, and Winter. The views expressed in the volumes do not necessarily reflect those of the editorial boards.

Getting to Here: Bioregional Federalism

By Wes Nicholson*

Within some complex systems, structures not determined at the top level or planned from the outset may nevertheless develop over time as emergent properties arising as a result of the self-organization of the system. Market economies are one such species of complex system. Environmental problems are among the byproducts of modern market economies. Accordingly, environmental problems are byproducts of complex, self-organizing systems.

This Comment posits that a complex, self-organizing system for establishing environmental policy would be more competent to thoroughly police environmental problems than a command‑and‑control system for establishing environmental policy. Proceeding, this Comment suggests that the establishment of boundaries of legal effect along environmentally significant lines, structured to exploit a sense of “place,” could result in a system under which environmental policy might self-organize. Such a “Bioregional Federalism,” related to but distinct from existing notions of bioregionalism, ecosystem management, and watershed management, could provide a systemic basis for self-organizing environmental policy.

This Comment concludes with an extended thought experiment exploring how Bioregional Federalism might be achieved.

 

I. Introduction

In the face of socioeconomic activity, the environment doesn’t take care of itself. Environmental degradation seems to be the default path of modern society absent conscious ameliorative efforts. Such conscious effort expended in pursuit of more environmentally protective policies can mitigate environmental degradation, but the cost in political capital can limit the scope, duration, and effectiveness of those policies. As a result, environmental problems emerge more quickly than they can be thoroughly policed. Our approach toward establishing environmentally protective policies leaves us chronically playing the part of a harried bureaucrat, running down the road after the problem, paperwork in hand.

This Comment posits that our system for establishing environmental policy has a structural problem that exacerbates all of our environmental problems, but that a structural mechanism may exist that could address this underlying structural problem. That structural mechanism lives in the overlap of two seemingly disparate political philosophies, one a product of the modern environmental movement, the other as old as the United States itself. The pairing may amount to a case of politics making strange bedfellows. However, there is evidence to suggest that the citizens of this country may be receptive to cross-ideological solutions to our pressing national problems.[1]

This Comment is speculative and exploratory in nature. Part II identifies our environmental problems in general as byproducts of a complex system. Part III first summarizes the philosophy of bioregionalism, as well as its more practically-minded relatives, ecosystem management and watershed management, then proposes a structural mechanism to mitigate these complex-system byproducts. Part IV is an extended thought experiment exploring how that structural mechanism, implementing a politics of place, might be achieved. Reflections on all of this follow in Part V.

II. Our Complex, Systemic Environmental Problem

A. The Persistent Difficulty of Environmental Problems

Generally speaking, environmental problems are a natural consequence of human industry. A business will have an environmental impact to one degree or another in the simple course of doing business.[2] The impact a business has upon the environment is not present as a force guiding its decisions in the same way as other forces acting on it, such as the need to secure funding, gain customers, and in general grow the business with a view to profits. At the same time, environmental impacts are not present as a force guiding governmental decisions in the same way as other forces faced by those in government, such as the need to discern and establish policies both proper and feasible on behalf of one’s constituency, most often in a partisan environment (and, perhaps, with an eye to preserving one’s own position and interest in government).[3]

Admittedly, a business may seek to become green, embracing business practices or developing products with an eye to reducing environmental impact. Admittedly, there are statutes and regulations outlining environmental policies, groups organized to petition the government for redress regarding environmental grievances, and factions in the electorate for whom environmental policy informs their votes—and thus pressures elected office-holders—to one degree or another.[4] However, all of this requires force of will to maintain. The green practices a business may embrace, or the development of environmentally minded products, may be subject to change in the face of conflict with more immediate interests of the business. Similarly, absent sustained political pressure, desirable environmental policies may never come to pass. Even where stated governmental environmental policies are at issue, countervailing political pressures may result in those environmental policies being given short shrift at enforcement time. Altruism is constantly subject to headwind forces.

At the same time, the difficulty of addressing many environmental problems is complicated by their cross-jurisdictional nature.[5] When the policies of more than one state or jurisdiction contribute to an environmental problem, the political will of all states or jurisdictions involved must be brought to bear in order to coordinate, negotiate, and reach agreement.[6] Thus, there is also a persistent barrier to entry for solutions to cross-jurisdictional environmental problems.

With respect to governmental policy, the forces set against altruism, as well as cross-jurisdictional barriers to entry, sap the will behind environmental policies. Assuming that industry will always be with us, environmental problems will always be with us. The establishment and enforcement of environmental policies will in turn always be hindered by dependence upon continuing political will.

B. Complex Systems, Self-Organization, and Emergent Properties

Complexity theory observes that some systems in which multitudes of independent actors are governed by simple rules may not only
possess surprising structural complexity, but may also be capable of self‑organization and self-regulation.[7] Such systems may have properties that are not direct results of the particular set of rules in the system, but that instead emerge as indirect, iterative, cumulative consequences of the operation of the system under that particular set of rules over time.[8]

A number of phenomena serve as examples of emergent properties of self-organizing, complex systems. Biodiversity may be seen as an emergent property of life under forces of evolution over vast spans of time—as one species succeeds and becomes plentiful, other species can succeed by relying on it as food, and the balance between populations of predator and prey becomes self-regulating over time.[9] The variety of languages may be seen as an emergent property of linguistic evolution among multitudes of peoples over time, constrained by an ingrained nature of grammar acting as the simple rules out of which complexity may arise.[10] The Internet in its current abundance came to be not because a government decreed its structure, but rather emerged because certain building blocks became available (URLs, servers, and site hosting services) and individuals, compelled by their own self-interest (ranging from hobby to profit) each built up one small part of it.[11] Even the Constitution may be seen to have implemented a system having emergent properties: Power is separated at the federal level into the three branches,[12] counting by design on the jealous tendencies of each branch to guard its own power to serve as a check on power’s inherent self‑aggrandizing nature,[13] an arrangement which is (mostly) self-regulating, and under its constraints, our complex government has evolved.

Similarly, a free market secures contracts and property rights, and the resulting system in its startling variety provides a mechanism—an imperfect mechanism, to be sure, but still an effective mechanism—by which employment, material wealth, and prosperity are created and distributed, generally speaking, for the greater part of its constituent members.[14] The  system does not specifically mandate these results. Instead, interestingly, a free market exploits the self-interest of individual actors therein, and the results emerge from the self-organizing system as it operates.[15] By relying on the inherent force of human self-interest, no force of will on the part of government is required in order to guarantee, by dictate, specific economic benefits. Instead, society seems guided as if by an “invisible hand” to act in such ways as to ultimately provide them.[16]

These benefits do not magically appear without any effort by any party. Indeed, to establish and run a business is a continuing act of will. However, the will involved is not the force of will exercised by a top-level actor (such as a government), but is rather the force of will of many actors distributed within the system, as guided by self-interest. Thus, in a market economy, from the perspective of top-level actors, solutions to economic problems appear to be self-organizing. That is, to a certain extent, economic problems seem to solve themselves.

C. Self-Organizing Environmental Policy

Our environmental problems are also the aggregate results of the acts of a multitude of independent actors. Individuals, businesses, and government may not set out to directly cause environmental impacts. Instead, they are byproducts of our social system. Since our social system fundamentally establishes a free market, those environmental impacts may be understood largely as being byproducts of a self-organizing, complex system. In other words, our complex, systemic problem is that our environmental problems as a whole are an emergent property of a complex, self-organizing system—a free market. Accordingly, it would be unsurprising if a command-and-control system for establishing environmental policy proved to be no more competent to thoroughly police those environmental problems than a command-and-control economy would prove to be in keeping pace with the underlying free market itself.

However, what if there was some force that our social system could exploit—analogous to the force of self-interest in a market system—that could guide the establishment of environmental policy? If it could be found, such a force could provide the basis for a systems-theory version of fighting fire with fire, or setting a thief to catch a thief. If the system establishing environmental policy could exploit such a force, perhaps an “invisible green thumb” could be set to tame the “invisible hand.” Doubtless, environmental policy would still require acts of will. However, if such a force could be exploited, from the perspective of top-level actors, solutions to environmental problems might appear to be self-organizing. Under such conditions, environmental problems might seem to solve themselves.

III. Exploiting Place Toward Self-Organizing Environmental Policy

In searching for a force to exploit in establishing self-organizing environmental policy, the philosophy of bioregionalism would be a profitable first stop. Bioregionalism maintains that political interests should be aligned with environmental boundaries.[17] Under the bioregionalist view, the inherently greater concern people are capable of having for their own immediate environment, as opposed to the concern people are capable of having for the environment in general, can act as a force for more environmentally sound policies.[18] Political decisions would therefore inherently come to take environmental considerations into account, as a result of living, so to speak, more directly in the “here” in which we find ourselves.[19] If this is true, then if bioregionalism were established, perhaps environmental policy could become self-organizing. However, bioregionalism as presently envisioned is extremely politically problematic.

A. The Bioregional Vision

Over twenty years ago, Kirkpatrick Sale summarized a vision for a social order capable of resolving the severe environmental stresses that characterize the modern world.[20] Under this social order, called bioregionalism, humanity would become “dwellers in the land,” approaching the environment with an admiration and respect born of “understand[ing] place, the immediate specific place where we live.”[21] This understanding would derive from knowing the constituent elements of the environment, understanding the limits to development that the environment can tolerate, and appreciating the relationship between human societies and the environment.[22] Ultimately, under a bioregional social order, the boundaries of social power would shift from political boundaries that have no particular relationship to the environment to bioregional boundaries existing in harmony with the environment.[23]

In the simplest case, bioregionalism might be conceived as the redrawing of political boundaries along more environmentally directed lines.[24] However, the extent and ambition of the bioregional vision described by Sale encompasses much more than a mere redrawing of boundaries. Sale described bioregionalism as being profoundly different from what he dubbed the “industrio-scientific paradigm.”[25]

As envisioned, bioregionalism is bundled with extreme changes to the social, political, and economic order. First of all, in a bioregion reoriented toward goals of conservation, stability, and cooperation, market structures would be abolished.[26] Economic activity would be communally directed and planned,[27] property would be communally owned,[28] and labor would be essentially selfless and community-directed, “performed without the idea of a wage return or individual benefit, indeed largely without the notion of ‘work’ at all.”[29]

Further, in such a bioregion, governance would be radically decentralized and organized around relatively small numbers of people (ranging in size from one thousand to ten thousand),[30] and would potentially aggregate into larger “confederate bodies.”[31] Such societies would be nonhierarchical, resembling tribal societies,[32] and the fundamental social values of some of those societies might depart disturbingly from traditional American or even western norms.[33]

Finally, the social fabric under bioregionalism would be vastly changed. Massive population dispersal would be undertaken in the course of establishing symbiotically dependent rural and urban areas.[34] Fashions would cease to be driven by the new and would instead be driven by
slow-to-change “images of sustenance and maintenance.”[35] Moral codes would be reoriented such that actions causing severe ecological harm would be classified on the order of murder and treated accordingly.[36] Even limited bioregional warfare, on the off chance that it were to occur, would be conducted in an environmentally cognizant, environmentally friendly way.[37]

As a practical matter, the achievability of any of these hard facets of the described bioregional vision lies between hard to imagine and flatly unrealistic. Beyond these hard facets, however, lie soft facets—attitudes and aesthetic trappings—that deepen the gulf between the vision and much of the body politic.

Beginning with appearances, a certain melodrama runs through the vision, from the description of the alternative to the industrio-scientific paradigm (“to become ‘dwellers in the land’”[38]), to the characterization of the scientific worldview as “our god,”[39] to the statement that “[t]he effect of scientific technology . . . has been to put a vast psychic distance between humans and nature,”[40] to his ultimate message that “[i]t behooves us . . . to give up those unearthly, demonic practices that threaten in so many ways the fundamental forms of life.”[41] Perhaps the vision is merely intended to be communicated to a fairly small audience, as a matter of preaching to the choir. However, the ideologically attuned presentation is likely to prove discordant to others.

Further “soft” facets of the vision may be even more difficult for the temperamentally skeptical to take. The vision evinces a fairly uncritical reverence of tribal life (both of Native Americans and of early or tribal societies elsewhere) that seems informed by “noble savage” sentiment.[42] At the same time, the vision greatly disparages the modern way of industry, economy, and society,[43] and presents something like a bioregional order as practically necessary to stave off impending environmental Armageddon.[44]

Of particularly grievous impact to the vision is its presentation, as a spiritual matter, of a necessity to preserve Gaea: not the colloquial “mother earth,” a “mother” only figuratively speaking, but rather “the earth mother,” a living entity whose personification is meant literally.[45] As the vision puts it, “We must try to learn that [Gaea] is, in every real sense, sacred, and that there is therefore a holy way to confront her and her works, a way of awe and admiration and respect and veneration that simply will not permit despoliation or abuse.”[46] The vision would seem to require that religious devotions be radically altered on the road to bioregionalism.

Other features of the vision can give a reader pause. It tends to acknowledge the difficulties inherent in many of his policy proposals, but then, having acknowledged the difficulties, it brushes lightly past them.[47] The work is dated, as well. The vision was captured in the mid-1980s, before the fall of the Berlin Wall, let alone the fall of the Soviet Union. Accordingly, its reliance upon such hard-socialist or communist standbys as economic planning is understandable. On the other hand, in light of the subsequent real-world failures of just the sorts of social models that are part and parcel of it, such policy prescriptions do not further endear the bioregional vision to modern audiences.

Under Sale’s bioregional vision, a simple redrawing of boundaries along environmentally friendlier lines is weighed down by a heavy cargo-load of far-left socioeconomic policy programs. To those already in agreement with most aspects of the vision, it may well sound both plausible and attractive. Accordingly, perhaps a small subset might rally behind the vision as stated. However, those not already in agreement will find much about which to be dismissive. Given that the supporting coalition would likely be thin, at best, the vision as it stands is little more than a pipe dream. A more widely palatable bioregional vision, if it could be found, would be required to make place a feasible force to consider exploiting toward self-organizing environmental policy.

B. Bioregionalism’s Cousins

The philosophy of bioregionalism did not arise in isolation from the rest of the world, and the same sorts of concerns that inform bioregionalism have informed similar notions, of which some have had more mainstream success. In the search for a more widely palatable bioregional vision, it may be instructive to examine two of bioregionalism’s cousins: ecosystem management and watershed management.

1. Ecosystem Management

a. Defined

Ecosystem management approaches land management policy from a regional ecosystem perspective. Ecosystem management views non‑ecosystem boundaries (such as state lines that might divide an ecosystem) as obstacles that must be overcome in the course of managing ecosystems, which are seen as units that are far more fit for analysis than traditional states.[48] Ecosystem management is characterized by increased interagency cooperation (including consultation and coordination), analysis of the impact of resource management proposals on ecosystems, commitment to preserving biodiversity, and commitment to preserving the aesthetic integrity of the environment.[49] Notable principles of ecosystem management include collaborative decision building, organizational change, and operating under a systems perspective.[50] Ecosystem management recognizes that people are part of an ecosystem and that human needs will play some role in the management of ecosystems.[51]

Ecosystem management is seen as a mechanism to deal with the mismatch between administrative boundaries and “meaningful ecological boundaries.”[52] It is seen as a means of addressing complicated problems,[53] of accommodating nondevelopment interests in lands,[54] and of holistically dealing with the full range of known environmental stressors.[55]

b. History and Current Practices

The roots of ecosystem management may be traced back at least to the late 1800s, when worries arose about the future of the nation’s natural resources in the face of rapid development.[56] In 1891, the Forest Reserve Act,[57] as modified by the later Organic Act,[58] provided “broad management authority” of public forest lands.[59] In 1905, Gifford Pinchot, the head of the Division of Forestry within the United States Department of Agriculture at the time, established the early principles of “multiple use and sustained yield management,” called “wise use,” under which lands were to be managed “from the standpoint of the greatest good of the greatest number in the long run,” although “good” was seen as primarily from the perspective of development, not what would modernly be seen as environmental or aesthetic concerns.[60]

The perception of what uses are “good” changed with the Multiple-Use Sustained-Yield Act of 1960[61] to include such things as recreational and aesthetic uses.[62] In the 1970s, “development” uses became further restricted.[63] In the 1960s and 1970s, both Yellowstone and the Great Lakes, respectively, were the subject of early ecosystem management efforts.[64] From these roots, “ecosystem management” as a formal idea arose in the 1980s and came to prominence in the 1990s.[65]

As of 1990, the federal government was beginning to experiment with ecosystem management.[66] The National Environmental Policy Act (NEPA)[67] was seen as imposing procedural requirements, if not substantive requirements, toward ecosystem management,[68] a position that was seemingly validated by the Supreme Court.[69] NEPA regulations were seen as requiring an accounting for the “cumulative impact” of the sorts of development proposals under consideration that might impact an ecosystem, leading to an evaluation of the aggregate impact upon the ecosystem of multiple similar development proposals.[70] NEPA regulations were also seen to require an assessment of “the impact of resource management decisions on shared ecosystems,” although courts were seen to have not “been eager to expand NEPA obligations beyond traditional jurisdictional boundaries.”[71]

By 1996, United States Forest Service regulations had incorporated ecosystem management principles,[72] and at least eighteen federal agencies were exploring ecosystem management.[73] In addition, 105 independent ecosystem management efforts were underway at various locations around the country,[74] primarily managed at the local level and directed toward specific problems.[75] States were also experimenting with ecosystem management.[76]

c. Prescriptions

Based on the available ecosystem management experiences, emphasis has been placed on making sure that nondevelopment uses are not lost among development uses in determining which uses should go forward.[77] One commenter saw a synthesis of concern for development and concern for ecosystem integrity, concluding that “[m]aintaining [v]iable [e]cosystems” would best serve development interests in the long run.[78] The importance of accounting for the effects of cumulative uses of the land was noted.[79]

Finally, the administrative nature of ecosystem management implies that the region being managed must be administrable. Interestingly, watersheds have been identified as among the more easily defined sorts of ecosystem, which may make them advantageously administrable.[80]

d. Problems

As it stands, ecosystem management is problematic. Without clear federal guidance, “ecosystem management” has had a range of meanings, particularly diverging among “biocentric” (directed toward environmental preservation) and “anthropocentric” (directed toward serving society) meanings.[81] Some perceive that ecosystem management could drift backward into “wise use,” with its attendant focus on social exploitation of environmental resources, unless it consciously directs itself toward environmental preservation.[82] Lack of funding for ecosystem management has been an issue.[83] The fact that nonprofits are deeply involved in many ecosystem management efforts has been seen as a point of concern with respect to “institutional design and accountability.”[84] Ecosystem management has also come under fire for radically departing from traditional governmental approaches involving fixed boundaries,[85] for being based on false notions that ecosystems can be nonarbitrarily defined,[86] and because the federal government is not a credible implementer of ecosystem management practices.[87]

Ecosystem management remains plagued by unresolved issues including vague policy goals, difficulties defining ecosystems, and difficulties defining the size and the position within a jurisdictional hierarchy of areas to be administered.[88] Significantly, ecosystem management still encounters difficulties accounting for “the interests and positions of numerous actors, both inside and outside of government.”[89] Despite the efforts of ecosystem management to overcome the misalignment of ecosystem and political boundaries, such problems remain. Decision makers “often face incredible political or administrative hurdles.”[90] The “numerous land management planning processes initiated by different federal and state agencies” waste precious time and resources.[91] Despite the best of intentions, lack of cooperation and “administrative red tape” remain problematic.[92] Coordination problems among federal and state participants have not disappeared.[93]

Interestingly, in a survey of ecosystem management efforts, the five most-cited outcomes were “procedural in nature.”[94] That’s a lot of procedure to move through before getting to results. Put another way, the problems of ecosystem management would seem to be centrally procedural in nature.

2. Watershed Management

a. Defined

Watershed management may be seen as one type of ecosystem management where the ecosystem in question is a watershed. Watershed management focuses on the water flowing into a river and the land from which that water flows.[95] Watersheds are seen as particularly apt ecosystems to serve as focal points for management efforts.[96] Although watersheds are much more concretely definable than other sorts of ecosystems, there is some variance as to what they encompass. In one sense, watersheds are basically river drainage basins.[97] However, watersheds may also be defined to include the soil and plants of the drainage basin, as opposed to (for example) the mere existence of a sloped contour of land down which water will run.[98] More finicky definitions distinguish between what might be called a “watershed proper” and other portions of a drainage basin, such
as catchments.[99]

As does ecosystem management, watershed management wrestles with the sorts of problems that arise when political boundaries are not aligned with watershed boundaries, such as cross-boundary coordination problems and interjurisdictional problems.[100] Watershed management is addressed to the full range of watershed stressors, such as timber harvesting, grazing, mining, and water diversions,[101] from the premise that if management is not undertaken at the watershed level, stressors in one part of a watershed might impact some other part of the watershed.[102]

b. History and Current Practices

As with ecosystem management, the roots of watershed management may be traced back to the late 1800s.[103] John Wesley Powell advocated that the American West be organized on the basis of watersheds.[104] “Watershed values”—specifically, the prevention of “destructive floods that result from inadequate forest cover”—were the basis for the Timber Culture Act of 1873.[105] Later, the President’s ability to reserve national forests was created by the Forest Reserve (or Creative) Act of 1891,[106] and the subsequent Forest Service Organic Act of 1897[107] declared that forest reserves were “established . . . to improve and protect the forest within the boundaries[] [and] for the purpose of securing favorable conditions of water flows.”[108] Interestingly, the Supreme Court’s decision more than eighty years later in United States v. New Mexico[109] found that water yield was the principal aim of the establishment of the National Forest system.[110]

Around 1900, the concept of “unified river basin management” took hold.[111] Unified river basin management, as the name suggests, was a watershed-level management philosophy, although one primarily directed toward development ends.[112] The years between 1900 and 1990 can be divided into three periods. In the first period, from 1900 to 1933, river basin management was oriented toward development uses, such as flood control, irrigation, and power generation.[113] Federal legislation established large projects in watersheds for development purposes.[114] Comprehensive watershed management legislation was considered but never adopted.[115]

In the second period, from 1933 to 1965, river basin management was oriented toward uses associated with economic improvement, such as hydropower.[116] Comprehensive watershed management legislation was considered again, during the New Deal, but not adopted,[117] and was considered and passed over yet again in the Truman and Eisenhower administrations.[118]

In the third period, from 1965 to 1990, a promising approach to cross‑jurisdictional river basin management was attempted by the Water Resources Planning Act of 1965 (WRPA).[119] In the end, this approach failed, largely because the provisions of the Act prevented it from exercising any real authority in cases of conflict with existing federal or state law.[120] Before failing, the Water Resources Council (established by the WRPA) reported that watershed management should be conducted by that level of government of the most appropriate scale.[121] At the same time, “watershed” was established as a coequal use among multiple uses for national resources planning purposes.[122]

c. Prescriptions

Since a watershed is impacted by uses within the river basin, watersheds (and watershed management) are important in general in multiple-use management analyses,[123] serving as an indicator of the “health of the land.”[124] Laws impacting watershed management are many and are related in complicated ways.[125] The abilities of a watershed management effort to cross political barriers[126] and establish cooperation among the relevant agencies[127] is important to effective watershed management.

One commentator has called for mandatory ecosystem and watershed management,[128] active local participation in watershed management projects,[129] and more effective implementation structures.[130] Another commentator has called for an embedded hierarchy of watershed management programs at various levels of “scale” in the hierarchy of a watershed (the way small streams feed into larger streams, or the way small governmental units such as counties are related to larger governmental units such as states),[131] as well as for local authority trumping federal authority on watershed management requirements.[132] The Committee on Watershed Management of the National Research Council has called for flexibility and responsiveness to local control[133] and “an era of flexible federalism” in which state and local governments would have substantial control over watershed management programs.[134] The Committee has also noted that coordination and cooperation will continue to be difficult to achieve unless real authority is vested in watershed management programs, and that in the meanwhile, the ad hoc arrangements that have characterized watershed management to this time may be the best arrangement possible.[135]

d. Problems

As with ecosystem management, watershed management efforts have their share of problems. Mission definition—whether development, or preservation, or both—is a source of difficulties.[136] There are difficulties defining the “watershed” to be managed.[137] Questions of whether an effort should be watershed management or ecosystem management also arise.[138]

Involvement on the part of the federal government brings problems as well. The “strong federal presence” required to enforce the management plan may not be appropriate and may act as a magnet for opposition, provoking “strong resistance.”[139] Finally, fragmented responsibility and dispute resolution methods in the event of interagency turf battles drag down watershed management programs.[140]

Again, as with ecosystem management, the misalignment of political boundaries and watershed boundaries is a major problem. It appears to be a larger problem for watershed management than for ecosystem management. Perhaps the relatively more definable nature of watershed boundaries, and therefore the more concrete nature of watershed management programs, clarifies boundary misalignment problems. Watershed management efforts are “difficult to create and, when established, tend to lack political viability.”[141] Perverse incentives may be inherent in the structure of some watershed management regions.[142] Cross-boundary coordination and cooperation is hampered by “frequent disagreements . . . with regard to water resources issues.”[143] Larger regions may see greater institutional conflicts and political rivalries.[144] Lack of system-wide policy coordination reduces watershed management effectiveness, leading to potential endangerment of the watershed.[145] The lack of alignment between watershed boundaries and political boundaries has negative political, institutional, and funding ramifications.[146]

Various levels of government jealously guard their spheres of authority, which hinders watershed management efforts.[147] Policy-wise, watershed management can be most effective if it impacts an entire river basin; but for large river basins, watershed management efforts impact and involve more stakeholders, which can lead to decreased cooperation and turf battles.[148] Finally, watershed management efforts under no federal coordination or direction (of the sort seen to date) can lead to a bewildering mess of various management schemes.[149]

C. A Different Bioregional Vision

When political jurisdictions and environmentally significant geographical partitions are not the same, environmental problems crop up. Initially, those problems are due to lack of coordination and cooperation among the various jurisdictions. It seems, however, that problems due to cross-jurisdictional governance exist even under modern ecosystem management and watershed management efforts. The bioregional vision of the 1980s is a nonstarter.  In the search for a more widely palatable bioregional vision that could exploit place toward self-organizing environmental policy, is there anything left? Perhaps the bioregional vision can be retooled. What if bioregionalism were stripped down to an essential constituent part? Posit a different bioregional vision, in which it is arranged to redraw political boundaries such as state lines to align them with environmentally significant partitions. Posit that this arrangement establishing bioregionally organized states is almost entirely structural and procedural in nature. In other words, the arrangement would purely concern itself with redrawing state boundaries, and would be utterly agnostic to specific, substantive matters of environmental policy. Such matters would include not only the many politically contentious facets of Sale’s bioregional vision, but even the question of where policy lines should be drawn between “biocentric” and “anthropocentric” values. Instead, the authority to make decisions regarding substantive matters of environmental policy would simply be granted to bioregionally organized states. What could be said about such an arrangement?

First of all, lacking the hard and soft facets of the original bioregional vision, the arrangement would be more palatable outside of the original vision’s narrow, sympathetic audience. There would be no radical reengineering of the fundamental nature of society, no quasi-religious aesthetic baggage—just the framing of the governing structure of society as squarely as possible with respect to the environment. (At the same time, although the bioregionally organized states would not be forced to adopt any of the hard or soft facets laid out by Sale, they would be free to do so under this different bioregional vision.)

Furthermore, the theories behind ecosystem management and watershed management suggest that even a relatively procedural change, such as establishing bioregionally organized states, could yield environmental benefits. Indeed, ecosystem management and watershed management are predicated on just such an outcome: Establishing bioregionally oriented states should have an inherent positive effect because the match between ecosystem and government jurisdiction, or between watershed and government jurisdiction, would be made more perfect, thus lowering potential barriers to entry to the establishment of environmentally protective policies.

In fact, a realignment of boundaries might address many of the problems observed under ecosystem management and watershed management programs. In bioregionally organized states, many vexing issues would become moot, or less pressing. There would be no need to repeatedly and artificially assemble interested parties, as must be done under ecosystem management and watershed management efforts. Rather, all interested parties in a jurisdiction would already have clear means of support for their involvement by virtue of the ordinary, usual, and traditional mechanisms for state governance. Accordingly, ad hoc management efforts would no longer need to depend upon the service—perhaps the altruistically rendered volunteer service—of interested parties since each bioregionally organized state would already have an infrastructure of representative government. There would be no need to coordinate and agree upon the “mission” of the management effort before the management effort could get underway, the continuously operative default mission being to choose between the range and mix of development and preservation uses available to the ecosystem or watershed. The question of funding would reduce to how much funding is given for any internal land management purpose, as opposed to rounding up impromptu sums in order to implement externally driven management efforts. The system of government need not radically change to mitigate observed procedural problems with management efforts; only the boundaries of the government need be any different than what has come before.

To be certain, environmentally favorable outcomes under such an arrangement would not be specifically guaranteed. That is to say, when choosing between development and preservation, a bioregionally organized state could pick a mix of uses less than one hundred percent preservation, since there is no accounting for the will of the people. However, that is true even presently. It would seem that, if anything, the playing field would be tilted more in favor of environmentally sensitive results than the status quo. Cross-jurisdictional barriers to entry for more environmentally minded policy would be minimized, and instead of needing to fight a procedural headwind, environmentally minded policies would have the wind at
their back.

In addition to the minimization of cross-jurisdictional barriers to entry, another force would likely affect environmental policy in each bioregionally organized state. Observation of the “NIMBY” (“Not In My Back Yard”) phenomenon suggests that jurisdictions resist development uses that may have environmental impacts within their borders.[150] In a bioregionally organized state, each decision of that state that could impact its associated parcel of the environment would result in the same bioregionally organized state living with the costs and benefits of that decision. A nationwide system of bioregionally organized states could result in an unbroken coast-to-coast patchwork quilt of backyards, each backyard encompassing an environmentally significant unit in which the NIMBY phenomenon would supply an inherent force toward environmentally protective policy. From the perspective of complexity theory, then, the redrawing of political boundaries in line with environmentally significant partitions could exploit forces related to place. Those forces—such as the NIMBY phenomenon, and reduced barriers to entry for environmentally minded policies—might create an invisible green thumb, by virtue of which solutions to environmental problems would be self-organizing; again, not in the sense that solutions would require no force of will, but rather in the sense that the top-level of the system need not specifically direct the shape and nature of those solutions to bring them to fruition. In so doing, the establishment of bioregionally organized states may provide a systemic mechanism to address our complex, systemic environmental problem. Under such a system, environmental problems might be adequately policed as, or before, they arise. Most significantly, while shedding various politically disadvantageous traits of the original bioregional vision, the establishment of bioregionally organized states would retain at least one highly politically advantageous trait. The original bioregional vision encompasses a decentralization of authority from a federal government to more local levels. This is in harmony with the modern federalist argument: Local control is better control.[151] Accordingly, not only might an arrangement of bioregionally organized states appeal to a wider segment of the left-hand end of the political spectrum, but adeptly presented, it could authentically appeal to a broad segment of the right-hand end, too; and an embrace wide enough to reach both ends of the spectrum might also encompass the vast swath in-between. A “grand bargain” marrying a bioregional arrangement so defined, and a federalist arrangement as modernly understood, could make this different bioregional vision—Bioregional Federalism—feasible, resulting in a system which is more sensitive to “the immediate specific place where we live.”[152] In establishing self-organizing environmental policy, Bioregional Federalism could guide our society to inherently live in a more environmentally responsible manner in the “here” in which we find ourselves.

Well.

How do we get “here”?

IV. Getting to Here

The redrawing of state boundary lines in an arrangement implementing Bioregional Federalism would constitute a change of extreme magnitude. How could such an arrangement be made maximally feasible?

As a preliminary matter, as discussed above, one fundamental problem of defining regions along environmental lines for any purpose is that such lines are inherently difficult to draw. Any bioregional boundary redrawing arrangement would therefore have to determine what should be the basis for defining the bioregions. Should they be defined by the range and mix of species found therein, for example? Alternatively, should they be defined by climate? Watersheds seem to be the most administrable method of defining bioregions. Therefore, the most feasible approach would probably be to define bioregions on the basis of watersheds.[153]

What other factors might theoretically shape the feasibility of an arrangement to redraw political boundaries along bioregional lines?

A. General Factors Impacting Feasibility

1. Constitutionality

As a threshold matter, one fundamental factor impacting the feasibility of an arrangement implementing Bioregional Federalism would be arguments about under what conditions the arrangement is constitutional at all. Could such an arrangement be validly enacted merely by federal statute? The Constitution stipulates:

New States may be admitted by the Congress into this Union; but no new State shall be formed or erected within the Jurisdiction of any other State; nor any State be formed by the Junction of two or more States, or Parts of States, without the Consent of the Legislatures of the States concerned as well as of the Congress.[154]

Given the clear text of the Constitution, if a bioregional arrangement were statutorily based, state boundary lines could not be redrawn with respect to any states refusing to participate in the arrangement.

Moreover, even with respect to states agreeing to participate, a statutorily proposed arrangement to implement bioregionally oriented states might provoke counterarguments that the arrangement is inherently unconstitutional. A general formalistic counterargument could be phrased in a number of ways. It might be argued that in the course of modifying state boundaries, the House of Representatives would cease to “be composed of Members chosen every second Year by the People of the several States,”[155] because subsequent to implementing a bioregional arrangement, one or more of “the several States” to which the text refers would no longer exist. An analogous argument might be made with respect to senators.[156] Furthermore, if a bioregional boundary redrawing resulted in adjustment to the jurisdictional boundaries within the federal judiciary, it might also be argued that the judges in any jurisdictions so affected might not be “hold[ing] their Offices during good Behaviour,”[157] because the changes to the boundaries of their jurisdictions constitute a removal of office. Essentially, these general counterarguments would maintain that the nature and substance of either the states or the federal government is changing in some way that subtly calls into question whether the structure of the states or the federal government under the new arrangement is constitutional at all.

A specific version of the general counterargument would refer to the language at the end of Article V that limits the range of permissible constitutional amendment by providing, inter alia, that “no State, without its Consent, shall be deprived of its equal Suffrage in the Senate.”[158] If a new arrangement is seen to have deprived a state of its equal suffrage in the Senate, then the arrangement’s constitutionality may be questioned.

If judicial review of the arrangement were sought on such grounds, the judiciary would have recourse to interpretive approaches that would remove such obstacles. For example, in the case of the general counterargument, a court could simply decide that the House of Representatives is, in fact, composed of members chosen by the citizens of the several states, even if that set of states has changed. Similarly, in the case of the specific counterargument regarding Article V, a court could simply decide that while the states have changed, if each new state has equal suffrage in the Senate, then the mere change from one set of states to another does not violate Article V.

Even given the flexibility of judicial review, a constitutional amendment may make a boundary redrawing arrangement more feasible, as any problematic constitutional provisions could be cast as having been either explicitly or implicitly altered by the amendment process. Amendment could allow a bioregional arrangement to apply even to holdout states.
In addition, amendment would lend strength to jurisprudential interpretations concluding that the arrangement merely and permissibly adjusts the states upon which constitutional provisions depend, rather than impermissibly dispossessing them. That additional support may help to overcome even the specific counterargument under Article V.

On the other hand, constitutional amendment requires overwhelming political will, which would reduce the feasibility of arrangements rooted in amendment. However, for purposes of clarity of discussion, it may be easiest to assume that the arrangement is established through constitutional amendment.

2. Degree of Change and Divisibility

Beyond constitutionality, other fundamental factors that would affect the feasibility of a bioregional arrangement would be, in a broad sense, the degree of change involved and the severability of the arrangement’s provisions.
Generally speaking, in any political matter, the smaller the change involved, the less political will is required to make the change. This is the same perspective that would judge the enactment of Sale’s bioregional vision as stated to be inconceivable, whereas a stripped-down, re-tuned bioregionalism focused solely on changing boundaries may be judged more feasible. If the changes involved even in a bioregional arrangement could be made smaller, or parceled into smaller pieces, they may be made
more feasible.

Divisibility of the arrangement would also impact its feasibility. To the extent that the changes involved can be applied piecemeal, the success of the enterprise as a whole may not be subject to the failure of any of its constituent elements. Additionally, if any portion of a bioregional arrangement could be enacted, at least some of the benefits of the arrangement may begin to accrue.

What other factors might shape the feasibility of a bioregional arrangement?

B. Specific Factors Impacting Feasibility

1. Changes to the Number of States

If those changes that are smallest are most easily accepted,
a bioregional arrangement preserving the number of states would be more feasible. A geographical region exerts influence within the federal government in two places: 1) in each house of the Legislature, and 2) in the number of electors used to elect the President.[159] If the states in a particular geographical region were to dissolve and re-form as a different number of states, the influence of that region within the federal government would either increase or diminish. In either case, replacement with a different number of states would be a source of discontentment with the arrangement and would reduce the political will in support thereof.

Consider the case in which an arrangement would cause the states in a region to re-form as a larger number of states. First, the Representatives associated with that region would shift within the region, as each new state’s share of the House of Representatives is settled. This consequence might be the least troublesome because, while the ratio of representatives to citizens might change for any subregion, the change to the region’s proportion of the House would likely be marginal.

However, a second consequence would be likely to have significant impact: If the number of states were to increase within a region, that region would gain more seats in the Senate. Not only would this increase the region’s influence in the Senate itself, but it would also result in increased influence in the presidential election process, as that region would have more electors than before. States outside the region would have their influence diluted, and would therefore be less likely to accept an arrangement which could include such a consequence.

There is a related difficulty in the case in which an arrangement would cause the states in a region to re-form as a smaller number of states. Again, representatives would shift within the region, but the change to the region’s proportion of the House would likely be marginal. However, the region itself would be faced with diminished influence in the Senate and the presidential election. States in that region would therefore be less likely to accept an arrangement that could include such a consequence.

An arrangement increasing or decreasing the total number of states might preserve the proportion of federal influence exerted by each region over the Senate, if the increase or decrease were uniformly applied, such as a proportional increase or decrease applied nationwide. For example, if each existing state were replaced by two new states in a bioregional arrangement, the resulting doubling of the number of states, and thus the doubling of the number of senators, would not change the proportion of any region’s influence over the Senate.

However, such a change may still encounter second-order problems. First of all, if an arrangement changed the number of senators (or, for that matter, the number of representatives), then the way in which business proceeds in the legislature would change. Procedures that have evolved and developed to accommodate the current number of members might need to change to accommodate a new number of members. Furthermore, the part played by each congressperson in “the life of the nation” would change if the size of the house in which he or she sits were to increase or decrease, which might provoke resistance to the arrangement. For example, each senator, currently in a position of high federal influence, would be less influential if there were twice as many as there are currently.

Finally, if the number of representatives did not change but the number of senators did (or if the two numbers changed by different ratios), the balance of power between relatively more populous regions and relatively less populous regions in determining the outcome of presidential elections would change, and could provoke resistance. For example, if the number of states increased, then the total proportion of the electoral college vote related to the number of senators would increase, increasing in turn the influence in the electoral college of regions whose fraction of federal political influence is governed more by the number of states therein than upon by the population therein.

2. Piecemeal Adoption Among the States

Allowing some regions to electively redraw their associated state boundaries without all regions doing so would increase the divisibility, and therefore the feasibility, of a bioregional arrangement. Boundary redrawing within any one region would not have to wait on the completion of a holistic boundary redrawing scheme in all regions. Delay might arise in a holistic arrangement where a contentious boundary redrawing in one region is held up by political interests. Delay might also arise where political interests in one region hold up boundary redrawing in another region. At any rate, the proliferation in the number of parties interested in the shape of the entire arrangement would increase the opportunity for contention.

3. Changes in Legal Authority and Changes in Law

Presuming that the boundaries of a state had been redrawn, what would be impacted? State legislatures pass statutes, state administrative agencies promulgate rules, and a state’s judiciary digests and interprets those statutes and rules.[160] However, the principle of least change would counsel that minimum change coincide with a new boundary arrangement. To force each new state to absorb massive changes of law over broad regions contained therein would represent precisely the sort of large change that should be avoided for the sake of feasibility.

Indeed, maintaining existing law upon changing boundaries would be consistent with the intent of the arrangement. An arrangement implementing Bioregional Federalism need not seek to establish environmentally infallible policies at the outset; rather, it would be forward looking, being designed to make future policies in a bioregionally arranged government more environmentally sound. It would be sufficient for boundary redrawing activities to merely establish new governmental authorities to create new policies, while retaining old policies until those new policies could be developed. Thus, if each subpart of a new state were to maintain the statutory, regulatory, and judicial law from whichever state previously contained that subpart, and if changes to the law of the new state as a whole were only incorporated incrementally as time moved forward, an undesirable extent of change could be mitigated.

4. Regions of Federal Legal Effect

Policies with environmental impact are not solely determined at the state level. At the federal level, the legislative branch makes laws, the executive branch promulgates rules, and the judicial branch creates precedent,[161] any of which could amount to or contribute to policies having environmental impact. In the bioregional vision, policies set at the federal level should also respect bioregional boundaries. For example, a constitutional amendment to establish a bioregional structure in federal policy-making bodies could be severed from any activities to reconstitute states along bioregional lines.

Even so, it is conceivable that bioregionally oriented boundaries that might be used to set policy at the federal level might not be the same as those used to set policy at the state level. Some current states contain many watersheds, and states subsequent to a bioregional arrangement may well also contain multiple watersheds or “lengths” of watershed; and there may be no reason that watershed-based boundaries of federal policy would necessarily be arranged to contain the same watersheds.

However, allowing watershed-based boundaries of federal policy to differ from watershed-based boundaries of state policy would run counter to the intent of the bioregional arrangement. If different federal policy-making agencies defined regions of federal legal effect with no thought to state boundaries or even regions defined by other agencies, the citizens of any given bioregionally oriented state might be forced to split their attention between multiple regions defined by, for example, the United States Environmental Protection Agency, the United States Army Corps of Engineers, the United States Bureau of Land Management, and the United States Fish and Wildlife Service, in order to competently interact with those various federal agencies in pursuit of sound environmental policy on behalf of their state.

It would be in greater harmony with the bioregional arrangement if the citizens of a single state would not have to divide their attention to policy matters between multiple regions of federal legal effect. Thus, any redrawing of boundaries of federal legal effect in a national bioregional arrangement ought to respect bioregionally oriented state boundaries.

5. Intrastate Bioregionalist Structure

Even if legal boundaries at the state level and federal level were aligned with respect to watersheds, there are other legal boundaries that would not be—namely, county and city boundaries, and also administrative boundaries within states. An amendment severable from the broader bioregional arrangement could address this, with reference to Article IV, Section 4 of the Constitution, by requiring that a “Republican Form of Government” mandates bioregionally oriented county boundaries as well (such as county boundaries determined with respect to watersheds).

There would be a potential problem with judicial enforcement of intrastate bioregional boundaries so determined: The Supreme Court held in Baker v. Carr[162] that claims related to the Guaranty Clause present nonjusticiable political questions.[163] In doing so, the Court relied on a couple of earlier cases. In the first case, Luther v. Borden,[164] the Court reasoned that since Congress must determine whether or not a state has a republican form of government before the state may enter the union, the responsibility for enforcing the Guaranty Clause rests with Congress.[165] In the second case, Minor v. Happersett,[166] the Court reasoned that since the Guaranty Clause does not spell out what it means by “Republican Form of Government,”
it has to look elsewhere to find out what that means, and concluded that the states have a duty to understand what that means in order to be able to supply it.[167]

These nonjusticiability concerns may disappear in the case of the aforementioned amendment to adjust the Guaranty Clause. First, under the amendment, new states could be admitted to the union not in the Article IV sense, but rather in the sense of being either “formed or erected within the Jurisdiction of any other State,” “formed by the Junction of two or more States,” or some combination of the two.[168] There is no addition of territory as implied by being “admitted,” merely a shifting.[169] Beyond that, the amendment itself could elaborate on what is meant by “Republican Form of Government,” in particular as it would apply to parties seeking judicial review with respect to bioregionally determined intrastate boundaries. Therefore, the amendment may be valid and sufficient grounds for the Court to adjust its Guaranty Clause doctrine.

6. Federalism: The Grand Bargain

Decentralization of governmental power is a strong theme of bioregionalism.[170] The basic idea is that local communities are best able to implement policies to look after the health of their own environmental regions.[171] This notion is cousin to current sentiments regarding centralized government power on the other end of the political spectrum. If a bioregional constitutional arrangement were looking for allies among a broader range of voters, a constitutional amendment to strengthen the decision-making authority of state governments in matters traditionally left to the federal government could be the key to establishing feasibility.
An amendment increasing state control of matters impacting environmental policy might increase support for the broader arrangement.

C. A Thought Experiment: Iterative Two-State Boundary Redrawing

1. Hypothesis

An arrangement that seeks to impose a specific bioregional structure from on high would be politically difficult, requiring as it would the sort of widespread agreement that has proven procedurally problematic in ecosystem management and watershed management. On the other hand, what may be a difficult question for a nation of states to resolve—how to determine bioregional boundaries over a vast geographical expanse—may be far easier for small sets of individual states to resolve in consultation and negotiation amongst themselves. If such negotiations could be carried out iteratively, for example, by dealing with boundaries between small sets of states independently, with the aim of growing a bioregional arrangement from the bottom up instead of imposing one from the top down, a bioregional arrangement might become more feasible.

a. State Representation in the Boundary-Redrawing Process

Assuming an iterative boundary-redrawing process, who should be involved in the consultations and negotiations? A fitting answer would be to have the existing states, or representatives of them, negotiate. Tying the decision-making process to states would have an added advantage of providing additional legitimacy at the level at which legitimacy would be needed, and therefore improving feasibility; to the extent that control over the actual process would be retained close to the people, support for the process would likely increase.

Presuming that negotiators representing the states were to direct the decision-making process, who ought those negotiators be? If they are left to be chosen by the governments of the states, those already holding positions in the government may be high on the list of candidates. However, the participation of such people in the decision-making process may be tainted by a desire to safeguard their own fortunes in government.

Article I, Section 6, of the Constitution contains a provision to prevent legislators from being positioned to exert unseemly influence:

No Senator or Representative shall, during the Time for which he was elected, be appointed to any civil Office under the Authority of the United States . . . ; and no Person holding any Office under the United States, shall be a Member of either House during his Continuance in Office.[172]

A similar provision to prevent negotiators acting on behalf of states in the decision-making process from being entangled in government (at either the state or the federal level) would help to ensure that those negotiators would be of, by, and for the people of the state.

b. A Two-State Method for Boundary Redrawing

Assuming that states are to be involved in the negotiations, and presuming that it would be advantageous to preserve the number of states, how should the negotiations proceed? Of the myriad ways to determine bioregions, watersheds have advantages due to their concreteness, but a watershed-based scheme is not without challenges.

First, at what regional scale should watersheds serve as guidance, and what sort of guidance should they provide? The continental United States does not contain an intuitively obvious set of forty-eight watersheds to be used as the basis for forty-eight bioregionally oriented states. Furthermore, consider the most prominent watershed in the United States: the Mississippi River. The Mississippi defines borders of nine states, and
its tributaries, such as the Missouri River and the Ohio River, define borders of more.[173] To both contain the entire Mississippi River watershed in one state and preserve fifty states would not only imply a state with a far greater share of federal political power than any current state, but would require a process by which a large number of states would need to be allocated to other regions in order to preserve their existence.

Such conditions might be less problematic if there were some way to split a watershed among more than one state. On the other hand, preventing the division of environmental boundaries is the general motivation behind an arrangement implementing Bioregional Federalism in the first place.
Could watersheds be split in a way that would not make a hash of the broader goals of the arrangement?

The general problem of allowing a water feature, such as a river, to serve as a political boundary is that all states sharing the river must coordinate to obtain effective environmental policy regarding the same stretch of river. This may be distinguishable from a scenario in which a single river flows through more than one state. In the latter scenario, “upstream” and “downstream” portions of a watershed could be spread between two different states, and one state acting alone would at least have sole discretion to set and enforce environmental policy with respect to the portions of the watershed draining from both sides into the associated portion of the river’s length. The resulting state boundaries would at least be more in line with the broader goals of the arrangement than current state boundaries. Interestingly, since the Constitution provides for extending judicial review to “Controversies between two or more States,”[174] if responsibility for the watersheds feeding into discrete lengths of a river were clearly apportioned, it may be easier to conceptualize addressing environmental controversies between states—for example, over water quality—through existing judicial mechanisms.[175]

Therefore, states might be preserved in a way that would not moot the larger bioregional arrangement if, in the course of arriving at the arrangement, the states were allowed to segment a watershed if required in order to “partition” lengths of a river. For example, for a given length of river bordered by any two states, a negotiation among those two states could establish an “upstream” portion of the river and a “downstream” portion of the river such that, for each portion, all land draining into that portion of the river (i.e., the watershed associated with that portion of the river) would reside in one state. Such a provision would accommodate bisection of a river in a manner aligned with watershed flow, allowing even large rivers, such as the Mississippi, to be split among multiple states.

Second, what specific procedures could constitute a reasonable process for determining new boundaries? This a question of fair division: How could all states in a region come up with a plan to fairly divide that region among themselves using watersheds as a guide? Consider the Mississippi River as an example again, and the nine states whose borders are, in some portion, defined by it. Should negotiators for all nine states gather together to discuss a new arrangement of boundaries? How would consensus be reached among nine parties? Any given length will be of little interest to most parties and of fierce interest to a few. Given that, who should propose the new set of boundaries? In determining a proposed new set of boundaries, what would ensure that the proposing party be both sufficiently interested in lengths of remote consequence and sufficiently disinterested in lengths of immediate consequence to make neutral and fair proposals regarding the full length of the watershed? Unless one state’s negotiators are given some special status, wouldn’t negotiators from each state be likely to make their own proposal, resulting in up to nine distinct proposals? How could states adequately evaluate a large number of likely divergent proposals and come to awell-grounded consensus on any one
of them? If these questions are then extended to include the many states that don’t directly border the Mississippi River, but drain into its tributaries, the difficulties explode.

The assumption that each state would be primarily concerned with those lengths of rivers most immediately tied to its boundaries suggests a solution. Assuming that a river defines a boundary between states, there will be a length of that river sufficiently small that it defines the boundary of only two states. At that granularity, if those two states could come up with some way to avoid splitting that watershed—unless to bisect it in a manner aligned with watershed flow—other states in the watershed may well not care. Additionally, if only two states are involved in a discussion to redraw a shared boundary, an easy answer to the fair division problem is available: one state divides, and the other state chooses.

Therefore, if the redrawing of political boundaries is broken down into a series of two-state fair-division problems, a complicated multistate fair‑division problem—one that may not be feasibly surmountable—could
be sidestepped.

c. A Method for General Boundary Redrawing

Assuming a two-state boundary-redrawing arrangement, how could it be incorporated into a continent-wide boundary-redrawing arrangement? What if iterations of the two-state fair-division arrangement are not sufficient to handle all cases? Congressional involvement in a continent-wide arrangement could help to smooth things out. First, Congress could enumerate the sets of boundaries between states that currently are not guided by watersheds. The list of boundaries not so guided is likely to include almost all existing boundaries, since it would include any boundaries described in part by a river or the shore of a lake, and any boundaries described in part by a straight line running latitudinally or longitudinally. This could define the range of redrawing activities to occur. Next, Congress could select the sets of boundaries to redraw, and the order of redrawing them, such that the related two-state negotiations could proceed simultaneously, and Congress could direct the whole process in order to conclude it on a certain timeline.

It could be important for the process to have a timeline—if the national will demands that the nation move in a bioregional direction, it would be unsatisfying if the process unfolded so slowly that its ultimate completion is called into question. However, some interstate negotiations may be complex enough, or the negotiators may be intransigent enough, that specific boundary negotiations may not be completed in a timely manner.

In order to handle cases in which states cannot come to agreement because of intransigence, but also to handle any case in which the redrawing activities are stalled (perhaps due to unforeseen conditions that may prohibit fair division), it could be beneficial to include a catch-all
“escape clause” giving Congress the ability to redraw a state boundary if the bordering states themselves are not able to do so. This might occur if two states were to realize that their existing watersheds would only result in a lopsided “fair division,” at which point the states might signal to Congress their resignation in the effort. Alternatively, if each two-state negotiation were allotted a set amount of time, the inability of two states to arrive at a “fair division” solution within that time might trigger the “escape clause” and cause responsibility for that specific redrawing activity to be handed over to Congress—which could be a powerful motivator to the states involved to complete the negotiation on their own. In such ways,
an “escape clause” provision could provide for timely resolution, through one mechanism or another, of all redrawing activities.

In a similar vein, it could be beneficial for Congress to take
time to study the broader arrangement before setting individual
two-state arrangements into motion. It may be that ordering the two-state arrangements in one way would lead to more tractable boundary resolution than ordering them in another way. However, random selection of two-state arrangements would be the means least amenable to
“gaming the system,” or exerting undue influence over the proceedings to any one state’s advantage. Therefore, if Congress were allowed to order the proceedings, it might be prudent to limit its ability to do so to such ordering that would minimize nontractable two-state arrangements.

d. Timeline

There is no reason that the mere close of negotiations in any particular two-state arrangement should imply that the new bioregionally oriented states thereby determined are ready to pick up their respective mantles of governance. Even if a newly created state government did not need to absorb changes in law over some portion of its regions, the new state may not have the legislative, executive, and judicial structure in place to promulgate any new policy. Therefore, some time ought to be allotted after creation of new boundaries for provisions and institutions of new governments to be created and prepare for governance.

e. Potential Amendments

Following are a set of hypothetical Amendments drafted with the above matters in mind, in which existing States choose representatives
to negotiate, as “States-in-Waiting,” in the establishment of new watershed‑based States.

AMENDMENT 1[176]

Section 1. When two States seek to redraw their boundaries in the manner provided for by this Amendment, said States sharing a boundary that splits a watershed in a manner described by this Amendment, the Legislatures of each State must Consent to the redrawing and report that Consent to the Congress; but no Consent of Congress shall be required to form or erect either new State resulting therefrom, and those new States shall be deemed admitted by the Congress into this Union in the time and manner described by
this Amendment.

Section 2. Before beginning the redrawing activities, the two States involved shall specify a date by which the redrawing activities will be concluded; but in no event will the amount of time from the Consent of the States to the end of the redrawing activities exceed four years.

Section 3. The citizens of each State involved shall choose, by apportioned vote, five persons to negotiate on behalf of that State, as a State-in-Waiting. All such negotiators shall meet the qualifications for service in the Senate of the United States; shall not occupy any civil Office which shall have been created under the Authority of either the United States or the patron State; and shall not be a Member of the House of Representatives of the United States, the Senate of the United States, or any legislative body of the patron State.

Section 4. Each State-in-Waiting involved will begin the redrawing activities with partial custody of the existing boundaries of its patron State. The two States-in-Waiting involved shall negotiate with each other with respect to the boundaries over which they each have partial custody in order to arrive at two redrawn sets of State boundaries, including a new boundary dividing the States; but no redrawn State boundary shall in any part split a watershed, unless to bisect it in a manner aligned with watershed flow. After reasonable negotiation, one State-in-Waiting, identified by chance, shall propose two new sets of redrawn State boundaries; and the other State-in-Waiting shall assign partial custody of the two sets of redrawn State boundaries to each of the two States-in-Waiting involved as it so chooses.

Section 5. No change in boundary should imply a change of legal authority at any geographical point until ten years after the resolution of State boundaries along watershed lines, at which point new boundaries shall attain legal effect.

Section 6. No change in boundary or legal authority should imply a change of law at any geographical point unless a newly constituted legal authority so deems, except that a State Constitution shall pass from each State to its associated State-in-Waiting. At that point, any legal authority whose sphere of authority contains law from more than one previous State may have free initial choice of law from any such previous source, in a manner consistent with the degree of discretion given to it in its institutional role.

AMENDMENT 2[177]

Section 1. Congress shall identify any State boundary that in any part splits a watershed, unless to bisect it in a manner aligned with watershed flow, as a State boundary to be redrawn.

Section 2. Within one year of passage of this Amendment, Congress shall determine the complete list of State boundaries to be redrawn, and shall determine therefrom an amount of time allowed for each phase of the general redrawing activities sufficient to permit all State boundaries to be redrawn, reserving sufficient time for itself to redraw any intractable boundaries; but the entire time from passage of this Amendment to completion of the redrawing of all State boundaries shall not exceed ten years.

Section 3. Congress shall study the general redrawing activities, and shall identify any boundaries that cannot tractably be redrawn through two-state negotiation unless some portion of the general redrawing activities proceed in an identifiably constrained order. In no event shall Congress take more than one year to determine the set of such boundaries and the ordering required to make them tractably redrawable by the States.

Section 4. Congress and the States-in-Waiting shall undertake the general redrawing activities in a series of phases, each phase comprising the activities in Section 5, until all State boundaries have been redrawn, or until the only remaining boundaries are not tractably redrawable by negotiation between States-in-Waiting.

Section 5. Subject to modification where required based on identifiable ordering constraints described in Section 3, Congress shall select through chance a State boundary to be redrawn, and in that manner continue selecting State boundaries to be redrawn subject to the following limits and constraints: Congress shall accommodate redrawing activities initiated by any set of two States but still in progress by including those boundaries among the first selection; No State-in-Waiting shall be involved in the redrawing of more than one of its boundaries in any one phase of the general redrawing activities; If a boundary chosen through chance is not tractably redrawable, that boundary shall be passed over until a subsequent phase; and Selection of boundaries in any one phase shall end when no State-in-Waiting with a tractably redrawable boundary remains. Once a set of boundaries to be redrawn has been selected, the redrawing activities will proceed as described in Amendment 1.

Section 6. If a negotiation does not end by the time allotted within the phase as set by Congress, the boundary in question will be deemed wholly intractable by the States, and will be removed from consideration in the general redrawing activities, to be reserved for resolution by Congress.

Section 7. At the end of the general redrawing activities, Congress shall redraw boundaries that were not tractably redrawable by the States in whatever manner it so chooses, taking care that the new boundaries do not in any part split a watershed, unless to bisect it in a manner aligned with watershed flow

Section 8. Once all State boundaries have been redrawn, custody of the final boundaries of each State-in-Waiting will be turned over to its patron State.

AMENDMENT 3[178]

Section 1. Congress shall not establish or suffer any boundary of federal legal effect—legislative, executive, or judicial—that divides a State; nor shall Congress establish or suffer any boundary of federal legal effect that in any part splits a watershed, unless to bisect it in a manner aligned with watershed flow, or unless that would prevent a boundary from being properly determined on the basis of population.

Section 2. Congress shall have ten years after the resolution of State boundaries along watershed lines to modify existing boundaries of federal legal effect in accordance with this Amendment.

AMENDMENT 4[179]

Section 1. In the United States, with respect to the several States, a Republican Form of Government shall be a form of government in which no boundary between counties, nor any boundary of State legal effect—legislative, executive, or judicial—shall in any part split a watershed, unless to bisect it in a manner aligned with watershed flow, or unless that would prevent a boundary from being properly determined on the basis of population.

Section 2. Each State shall have ten years after the determination of county boundaries along watershed lines to ensure a Republican Form of Government within that State.

AMENDMENT 5[180]

No policy that may affect the environment in a given region will have legal effect unless it is established both by the State government associated with that region and the federal government.

2. Experiment

How might a boundary-redrawing arrangement unfold under these rules? Following are two test cases of specific iterations of two-state boundary redrawing according to the arrangement established by the amendments above.

a. Negotiating States: Oregon and Washington


Figure 1: Oregon and Washington

As seen in Figure 1, the border between Oregon and Washington is prominently defined by the Columbia River. The starting point would be to examine the region in terms of its watersheds. To a rough approximation, where two water features are separated on this map, some geographic feature divides them such that one side of the divide drains through a watershed into one water feature, and the other side of the divide drains through another watershed into the other water feature.

Figure 2: Oregon and Washington, with
Approximated Watershed Divisions

 

 

In Figure 2, approximated watershed divisions in the region of the Columbia River have been added (see the light dashed lines). Under the “one state divides, and the other state chooses” mechanism described in the Amendments, if one state-in-waiting proposed a new set of state boundaries establishing a northern state encompassing all of the Columbia River (although perhaps not all its watersheds), the other state-in-waiting would likely seek to claim that northern state, since it would not merely contain all the Columbia, but would include politically, socially, and economically key territory, such as the areas around the northern Willamette River (including Portland) and the greater Seattle-Tacoma metropolitan area.

Figure 3: Oregon and Washington, with Approximated
Watershed Divisions and Proposed New Boundaries

 

Therefore, self-interested proposals would likely look to establish a boundary that bisects the Columbia in a manner aligned with watershed flow. In that event, a couple of different arrangements might be considered: a first arrangement including a redrawn state encompassing both the Willamette River watershed and the watershed containing the Seattle-Tacoma area, but consciously attempting to limit the geographic area of that state in order to make the remaining state as large as possible (see the heavy dotted line in Figure 3); and a second arrangement including a redrawn state encompassing the Willamette River watershed, but not the Seattle-Tacoma watershed, and dividing up the remainder of the states as fairly as possible in that context (said fair division being likely to allocate more land to the Willamette River region, given the size in population and financial terms of the Seattle-Tacoma area with respect to the Portland area) (see the heavy dashed line in Figure 3). The second arrangement might be more likely, since each set of negotiators would likely prefer at least one area of high population, given that two are available.

b. Negotiating States: Tennessee and North Carolina

Figure 4: Tennessee and North Carolina

 

 

As seen in Figure 4, the border between Tennessee and North Carolina is not defined by a prominent river. Instead, it is a case where the existing border largely appears to already exist between watersheds. In this case, an adjustment of the border to not split watersheds except in a manner aligned with watershed flow might merely amount to shifting the existing border (see the heavy dotted line and heavy and dashed line in Figure 5).

Figure 5: Tennessee and North Carolina, with Approximated Watershed Divisions and Proposed New Boundaries

Precisely which new boundary line would be agreeable to both states would depend upon how closely the existing boundary line hews to a watershed division. If the watershed division is such that it is primarily to the east of the existing boundary line, a first arrangement compensating on the northern end of the new boundary for land “lost” by North Carolina on the southern end of the new boundary might be more likely. On the other hand, if the watershed division is primarily to the west of the existing boundary line, a second arrangement compensating on the northern end of the new boundary for land “lost” by Tennessee on the southern end of the new boundary might be more likely.

3. Conclusions

The largest drawback of an iterative two-state arrangement implementing Bioregional Federalism is that it may not satisfy what might be called a “bioregionalist aesthetic.” The states that result from this process will have boundaries that have shifted; but under the constraints of both preserving fifty states and centrally involving the states in the redrawing exercises, each state may be related to more than one watershed, and include some portion of, but perhaps not all of, any one of those watersheds. This is not as theoretically pleasing as a clean, one-to-one mapping of watershed to unit of political control would be. Not only that, but once the process is complete, the boundaries will have changed, but the vertices in the “network” of boundaries—the corners between the states—will be the same; and if there was no reason to trust that borders defined by water features or by latitude or longitude lines would lead to a harmonization between politics and environmental concerns, there may similarly be no reason to trust that the vertices between them would, without more, be harmonious themselves. Finally, the range of watersheds (and perhaps portions of watersheds) in a new state might not have a clean relationship to some of the other potential measures of a bioregion, such as climate conditions or species mix and distribution.

One possible partial cure would be to initiate a process in which more than two states would negotiate a new arrangement at once. This would have the advantage of potential flexibility even at the vertices. However, as discussed above with respect to the example of states in the Mississippi River watershed, the fair division problem becomes much more complicated once it involves more than two parties, especially when (as would be the case here) it is not a mere matter of divvying up an area, but rather divvying it up into geographically intact parts.

Another possible partial cure would be to wipe the slate clean and not worry about preserving fifty states. An arrangement so based would involve much more significant change, and would therefore require more social agreement before it could become feasible. A middle ground might be for Congress to wipe the slate clean but commit itself to finding fifty regions, which would preserve the number of states while allowing for more direct conformance to a “bioregionalist aesthetic.” However, either case would hand Congress a massive political and logistical problem and demand that Congress solve it, which would require a great deal of trust in its institutional competence, and which may reduce the feasibility of
an arrangement.

On the other hand, even if the amendments above led to an arrangement on the “warty” side of the “bioregionalist aesthetic,” it would still be less “warty” than what exists now. Given the multiple ways in which bioregions might be drawn, it is already certain that there is no such thing as a perfect set of bioregional political boundaries. Perhaps the arrangement would be only a step, but it may be a step in the right direction—although the question would remain of whether the step is significant enough to justify the pain involved in taking it.

V. Reflections

In exploring the establishment of bioregionally oriented states as a means of establishing self-organizing environmental policy, this Comment makes no claims of infallibility. With luck, it points out some of the major forces that would shape such an arrangement and some features that might make the arrangement more feasible in light of those forces. Even lacking the hard and soft aspects of the original bioregional vision, Bioregional Federalism alone would seem to involve changes of such extreme magnitude as to make even a maximally-feasible bioregional arrangement seem implausible. Hopefully, this Comment may serve to suggest by way of example (albeit perhaps by poor example) that such things are thinkable.

Whatever the strengths of Bioregional Federalism may be, the prospect of addressing our complex, systemic environmental problem is appealing.
If a system could be established in which environmentally protective policies were self-organizing, environmental problems might seem to solve themselves. At the same time, absent some mechanism in support of self‑organizing environmental policy, a command-and-control system for establishing environmental policy may be inadequate to deal with the environmental impacts that are the byproducts of a complex system—meaning, the byproducts of our market economy. This may in turn force unhealthy political reactions to environmental problems.

As tends to be true for political matters in general, environmental policy to correct environmental impacts will be, to the extent left to political solution, defined by partisanship, and will not be strongly related to rational, broadly undertaken discourse.[181] Under such conditions, environmental impacts may beget environmentally sensitive yet partisan responses, needlessly increasing political animosity in the process. Ugly thought and word may build upon ugly deed to the detriment of potentially more harmonious solutions, until the environmental situation becomes dire enough that shocking and extreme measures are imposed. Perhaps the most important aspect of self-organizing environmental policy would be its service as a bulwark securing freedom from its own potential excesses.

There may be real environmental value to Bioregional Federalism in achieving self-organizing environmental policy, but any realistic proposal would require much further thought. There would certainly be legal effects and consequences, some no doubt profound, that this Comment has not suspected. No course of action that is ill-thought-out can claim the auspices of wisdom. Accordingly, to any who may be intrigued by the potential of self‑organizing environmental policy in general, or by the potential of this different bioregional vision in particular, this Comment issues a call to armchairs.



* Form & Style Editor, Environmental Law, 2008–2009; Member, Environmental Law, 2007–2008; J.D. 2009, Lewis & Clark Law School; S.B. 1996, Massachusetts Institute of Technology. All underlying maps are derived from U.S. Geological Survey, U.S. Dep’t of the Interior, National Atlas of the United States of America: Rivers and Lakes (2003), available at http://www-atlas.usgs.gov/printable/images/pdf/outline/rivers_lakes.pdf. Comments and questions may be directed to the author at wesley09@lawalumni.lclark.edu. The author thanks Professor Steve Kanter and Professor Peter Nycum for guidance and feedback regarding earlier drafts of this Comment. The author also thanks the staff of Environmental Law for their rigorous and gracious editorial assistance. Finally, the author wishes to thank his parents, Wes and Sue Nicholson, for their care; his sister, Jeanette Wiersma, for times shared; his children, James and Blakeley, for providing the reasons; and his wife, Pamela, who makes all things possible.

[1] President Barack Obama, Inaugural Address (Jan. 20, 2009) (transcript available at Posting of Macon Phillips to the White House Blog, President Barack Obama’s Inaugural Address, http://www.whitehouse.gov/blog/inaugural-address (Feb. 20, 2009, 13:27 EST) (last visited Apr. 18, 2010)) (“On this day, we come to proclaim an end to the petty grievances and false promises, the recriminations and worn-out dogmas that for far too long have strangled
our politics.”).

[2] Richard York et al., Footprints on the Earth: The Environmental Consequences of Modernity, 68 Am. Soc. Rev. 279, 279 (2003).

[3] See, e.g., Posting of John M. Broder to The Caucus, Climate Change Bill Is in Doubt, http://thecaucus.blogs.nytimes.com/2010/01/20/climate-change-bill-is-in-doubt (Jan. 20, 2010, 18:55) (last visited Apr. 18, 2010) (discussing significant scaling back of energy and climate change legislation pending in Congress in order to “focus[] more on job-creating technologies than on limiting climate-altering pollution”). See generally David R. Jones, Position Taking and Position Avoidance in the U.S. Senate, 65 J. Pol. 851, 851 (2003) (discussing how the roll-call votes in the Senate are “significantly related to factors such as diversity of constituents’ opinions, pursuit of higher office, electoral marginality, retirement decisions, and visibility within the institution”).

[4] See, e.g., National Environmental Policy Act of 1969, 42 U.S.C. §§ 4321–4347 (2006); Sierra Club, Environmental Law Program, http://www.sierraclub.org/environmentallaw (last visited Apr. 18, 2010) (describing the legislative and judicial efforts of one organization working on environmental issues).

[5] See George Francis, Ecosystem Management, 33 Nat. Resources J. 315, 344 (1993) (“‘Ecosystem management’ poses a special challenge to boundaries. Boundaries associated with jurisdictions, administrative districts, and ownerships artificially transect ecosystems. While the international boundary is important for historical and other reasons, in the case of the Great Lakes it has also served as a perceptual and psychological boundary, impeding the development of a shared understanding of a major bioregion.”).

[6] See id.; see also Robert W. Adler, Addressing Barriers to Watershed Protection, 25 Envtl. L. 973, 991–92 (1995) (“[W]ater resource programs logically should be organized according to watershed boundaries. Politically, however, this has been difficult because each level of government guards its authority jealously. . . . [A]s described by the Natural Research Council Restoration Committee: ‘ . . . The politics and consensus building required for integrated resource management of the resource are often as complex as the ecosystem itself.’”); Charles  H.W. Foster, Bioregionalism: Cooperation to Live By, Alb. L. Envtl. Outlook, Winter 1996, at 13, 15 (“A heritage of intergovernmental mistrust seemed to dim any hope for true multi-jurisdictional action . . . .”); Michael V. McGinnis, On the Verge of Collapse: The Columbia River System, Wild Salmon and the Northwest Power Planning Council, 35 Nat. Resources J. 63, 65 (1995) (“In many respects, the plethora of entities, interests and individuals responsible for developing restoration strategies creates additional problems for a comprehensive ecosystem restoration effort.”); Paul S. Weiland & Roberto O. Vos, Reforming EPA’s Organizational Structure: Establishing an Adaptable Agency Through Eco-Regions, 42 Nat. Resources J. 91, 98 (2002) (“Human boundaries confound efforts to manage human-environment relations. To overcome the problems associated with such boundaries, it is necessary for people and institutions to cooperate. Cooperation to protect or enhance the natural world is only possible after parties have agreed that cooperation is necessary and specified the nature and extent of such cooperation. This agreement may be elusive due to value differences and scientific uncertainty.”).

[7] See Stuart Kauffman, At Home in the Universe: The Search for Laws of Self‑Organization and Complexity 8 (1995).

[8] See id. at 24 (stating, with respect to the author’s theory about the chemical nature of life, “If true, then life is not located in the property of any single molecule—in the details—but is a collective property of systems of interacting molecules. . . . Life, in this view, is not to be located in its parts, but in the collective emergent properties of the whole they create”).

[9] Id. at 115 (“But while the biosphere as a whole is supracritical, . . . the individual cells that make up the biosphere must be subcritical . . . . This, I will try to persuade you, is the source of the creative tension that brings about the ever-increasing diversity of the biosphere.”).

[10] See Jack Cohen & Ian Stewart, The Collapse of Chaos: Discovering Simplicity in a Complex World 174 (1994) (“Language exploits, and may even have arisen from, a trick that our brains seem to find natural in any case.”).

[11] See Fed. Commc’ns Comm’n, History of Communications—Internet: Common Standards, http://www.fcc.gov/omd/history/internet/common-standards.html (last visited Apr. 18, 2010) (discussing the “explosive growth” of the Internet upon the formal decommissioning of ARPANET in 1990 and charting the growth in the number of internet hosts from 100,000 in 1990 to 1,000,000 in 1992); Nat’l Acad. of Eng’g, History of the Internet, http://www.nae.edu/cms/
8743.aspx (last visited Apr. 18, 2010) (detailing the use of the internet to “search thousands of databases and libraries worldwide in several languages, browse through hundreds of millions of documents, journals, books, and computer programs,” as well as to follow news, shop online, and pay bills); Ian Peter, History of the World Wide Web, http://www.nethistory.info/
History%20of%20the%20Internet/web.html (last visited Apr. 18, 2010) (discussing the “massive growth” of the Internet “[e]very year from 1994 to 2000” and the development from being “mainly used for displaying information” to including some 750,000 commercial sites showing “the power of the web as a sales medium”).

[12] U.S. Const. art. I, § 1; id. art. II, § 1; id. art. III, § 1.

[13] Akhil Reed Amar, Five Views of Federalism: “Converse-1983” in Context, 47 Vand. L. Rev. 1229, 1237 (1994).

[14] See generally Cheyney C. Ryan, Yours, Mine, and Ours: Property Rights and Individual Liberty, 87 Ethics 126, 127–28 (1977).

[15] See generally Adam Smith, Wealth of Nations 400 (J.M. Dent & Sons Ltd. 1977) (1776) (explaining the relationship between promoting one’s own self-interest and the interest
of society).

[16] See id. (“By preferring the support of domestic to that of foreign industry, he intends only his own security; and by directing that industry in such a manner as its produce may be of the greatest value, he intends only his own gain and he is in this, as in many other cases, led by an invisible hand to promote an end which was no part of his intention.”).

[17] Foster, supra note 6, at 13.

[18] Id. at 14.

[19] See Kirkpatrick Sale, Dwellers in the Land: The Bioregional Vision 97 (1985) (“Even if we haven’t modern experience to ratify it entirely, the logic certainly suggests that because bioregional governance stands in a direct and vital relation to the natural environment and its resources, and because it can deal with a population of cultural and ecological homogeneity, it can do more effectively for the populace those things that governments are supposed to do.”).

[20] See generally id. at ix–x, 37 (describing the modern state of environmental crisis resulting from “an industrio-scientific worldview”).

[21] Id. at 42.

[22] See id.

[23] See id. at 55–59, 66 (discussing various hierarchical “scales” at which the environment can be partitioned into regions); id. at 97 (“[B]ecause bioregional governance stands in a direct and vital relation to the natural environment and its resources, and because it can deal with a population of cultural and ecological homogeneity, it can do more effectively for the populace those things that governments are supposed to do.”).

[24] Id. at 94–95.

[25] See id. at 50.

[26] See id. at 82 (“[T]he marketplace of our traditional capitalist economy, with its emphasis on competition, exploitation, and individual profit, needs to be phased out.”).

[27] See id. at 76 (explaining in regard to a bioregion’s efforts to achieve self-sufficient sustainability that “[t]hese kinds of adjustments need not be sudden, or hard, or privative, and they could be planned with great care and sophistication once the bioregional stocks and supplies are fully known.”); id. at 79 (“Self-sufficiency . . . is not the same thing as isolation, nor does it preclude all kinds of trade at all times. It does not require connections with the outside, but within strict limits—the connections must be nondependent, nonmonetary, and noninjurious—it allows them.”).

[28] See id. at 84–85 (“[T]here would be a sense that the wealth of nature is the wealth of
all—people should not be able to own the land, or its ores, or its trees, any more than they can own the sky and its clouds—and whatever is taken from Gaea’s realm is not to be hoarded and used for personal glory but distributed and used for regional benefit.”); id. at 85 (“Ownership . . . might logically be in community rather than regional or individual hands . . . .”).

[29] Id. at 84.

[30] Id. at 94–95.

[31] Id. at 96 (explaining that among communities in a bioregion, “possibly some kind of political deliberative and decision-making body would eventually seem to be necessary”).

[32] See id. at 97–102. “Hierarchy and political domination would have no place; systems of ruler-and-ruled, even of elected-president-and-electing-people, are nonecological. . . . No leader, no ruling committee, no oligarchy, only citizens performing necessary roles . . . .” Id. at 101.

[33] See id. at 104–10 (“Bioregional diversity . . . does not mean that every community in a bioregion . . . would construct itself along the same lines, evolve the same political forms. Most particularly it does not mean that every bioregion would be likely to heed the values of democracy, equality, liberty, freedom, justice, and the like, the sort that the liberal American tradition proclaims. . . . Different cultures could be expected to have quite different views about what political forms could best accomplish their bioregional goals, and . . . those forms could be at quite some variance from the Western Enlightenment-inspired ideal.”).

[34] See id. at 113–16 (indicating that for cities of more than an “upper limit” of 250,000 people, “there seems to be no sensible choice but to break down the current multimillion-people cities both by dividing them into smaller cities . . . and by resettling them into different-sized communities in the surrounding region,” and that this “population relocation” would affect one-fifth of the U.S. population among 48 cities).

[35] Id. at 119.

[36] See id. at 120 (“Greatest opprobrium, and presumably punishment, would attend those acts that are most violent and disruptive, that cause severe or permanent damage to the ecosystem, no matter what supposed economic or material benefits they may offer—such as murder or clearcutting or species extinction or the introduction of the gypsy moth.”).

[37] See id. at 127.

[38] Id. at 41.

[39] Id. at 21.

[40] Id. at 22.

[41] Id. at 192.

[42] See id. at 60–61 (discussing “American Indian habitation in bioregional patterns” as a demonstration of the firm grounding of the bioregional vision since “it is a concept inherent in the cultures of age-old peoples who knew the ways of nature best”); id. at 81–85 (stating that “what we take for granted in our market system . . . is really a rather recent development,” and that “the simple economies of most societies before the modern age . . . seem to have much that a bioregional society could learn from,” perhaps as a result of the nature of such social systems whereby “no activity is undertaken that is not a custom or a ritual or a spontaneous part of social congress, and where seldom does anyone have to be forced or coaxed to perform it”); id. at 99–101 (describing “preliterate cultures” as lacking such unsavory elements as “those ‘organized stratifications’ we have become accustomed to in the industrial world,” meaning hierarchical relationships).

[43] See, e.g., id. at 28 (“[T]he economy is based precisely on the concepts of exploitation, productivity, and growth.”); id. at 29 (characterizing industrialized agriculture as “reckless”); id. at 48 (describing the notion in industrial society “of controlling and remaking the world in the name of a global monoculture” and characterizing industrial economy as “imperiling” humanity).

[44] See id. at 12–37 (“I take what little comfort I can . . . from the belief that we have at our grasp the instrument—the philosophy, if you will—by which to begin to rescue . . . our beleaguered species, creating for ourselves . . . an ecological worldview with which to replace the scientific worldview . . . that has so imperiled us. That instrument, that philosophy, is the bioregional vision.”); id. at 192 (advocating the implementation of the bioregional vision “[b]ecause what other choice, really, do we have?”).

[45] See, e.g., id. at 3–11 (“In all the long stretch of human history . . . the people of this planet saw themselves as inhabitants within a world alive.”); id. at 183–92 (“And so, after all, the Greeks seem to have been right. There is no real doubt about it: the earth, the biosphere, is alive, ‘a living creature, one and visible, containing within itself all living creatures.’”).

[46] Id. at 41–42.

[47] See id. at 48–49 (noting that the bioregional vision “is so at odds with the conventional way of looking at the world nowadays that it must strike most people at first as either too limiting and provincial, or quaintly nostalgic, or wide-eyed and utopian, or simply irrelevant—or all of those,” and while continuing to describe the improbabilities involved, concluding that he is “certain that in the bioregional paradigm we have a goal, a philosophy, and a process” that is “not only necessary for the continuation of our species, but is also desirable and possible”); id. at 179 (“The bioregional project, then, certainly has its full measure of dreams of things that never were; yet when properly understood in its totality, it is not in any sense fantastical, chimerical, quixotic, or illusory. I do not suggest that it is inevitable or fated, or that once begun it could not be frustrated and defeated; just that it is without doubt possible.”). Ironically, Sale writes, “[T]he bioregional project has the virtue of realism. It does not demand any elaborate wrenching of the physical or human conditions of the world we know, any fantastic alterations of nature-as-it-is or people-as-they-are.” Id. at 177.

[48] See Robert B. Keiter, NEPA and the Emerging Concept of Ecosystem Management on the Public Lands, 25 Land & Water L. Rev. 43, 43 (1990) (“Modern science has revealed that dynamic, complex ecological processes are a vital and important part of the natural environment, and that neither biological processes nor environmental phenomena respect conventional boundary lines. Indeed, virtually all of the natural resources found on the public domain are part of ecosystems that extend beyond established legal boundaries.” (footnote omitted)); id. at 45 (“The evolving concept of ecosystem-based management is still in its formative stages and remains rather ill-defined. As a general principle, ecosystem management views public lands and resources from a regional or resource system perspective; it regards natural phenomena, such as watersheds, airsheds and wildlife habitats, as the appropriate focus for management decisionmaking. . . . In short, management priorities—set in accordance with ecological principles—should transcend jurisdictional boundaries and reflect an overarching commitment to an integrated public domain.”).

[49] See id. at 47–50.

[50] Richard Haeuber, Setting the Environmental Policy Agenda: The Case of Ecosystem Management, 36 Nat. Resources J. 1, 4–5, 26–27 (1996) (noting that “a generally accepted set of [ecosystem management] principles, or components, has emerged” out of past regional-scale management efforts that have not been consciously “ecosystem management,” with these principles being sustainability, systems perspective, broad spatial and temporal scales, humans as ecosystem components, socially defined goals and objectives, collaborative decision building, organizational change, adaptive management, monitoring, and data collection).

[51] See Scott W. Hardt, Federal Land Management in the Twenty-First Century: From Wise Use to Wise Stewardship, 18 Harv. Envtl. L. Rev. 345, 392 (1994) (“As a result of our dependence on resources harvested from our environment, human society is a significant force in shaping the world’s environment and must be considered part of the ecological community being managed. . . . Consequently, human use of natural resources and the creation of human-induced successional stages should be considered an appropriate element of ecosystem management . . . .” (footnotes omitted)).

[52] See id. at 393 (“To manage ecosystem viability effectively, federal land managers . . . will need to adjust the geographic areas over which they make multiple use decisions since administrative boundaries seldom reflect meaningful ecological boundaries.”).

[53] See Haeuber, supra note 50, at 2 (“The generation of environmental issues now upon us, however, are defined by greater political, economic, social, and even cultural, complexity. They include difficult scientific questions, such as appropriate scales for resource management; thorny administrative matters, such as inter- and intra-governmental relations; political controversies surrounding land use planning and property rights; the problems involved in restructuring of natural resource-based economies; and the cultural underpinnings of ranching, logging, fishing and other traditional resource dependent communities.”).

[54] See Jack Ward Thomas, Foreword to Ecosystem Management: Applications for Sustainable Forest and Wildlife Resources, at ix, x (Mark S. Boyce & Alan Haney eds., 1997) (“Emergence of ecosystem management is a consequence of conflicts over how we manage our public lands. The American public will no longer tolerate commodity-production priority for managing our national forests and other public lands; neither can we afford to exclude commodity users from public lands and support a human population of 5.6 billion people.”).

[55] See Steven L. Yaffee et al., Ecosystem Management in the United States: An Assessment of Current Experience 9–11 (1996) (listing “anthropogenic ecosystem stresses,” including hydrologic alteration; land conversion to urban use; agricultural practices; disruption of fire regime; nonpoint source pollution; grazing and range management; timber and forest management; land conversion to agricultural uses; recreation; point source pollution; mining; and overfishing, overhunting, or overcollecting).

[56] See Hardt, supra note 51, at 350 (“An affirmative policy of federal land management began evolving in the late nineteenth century only after a century of uncontrolled exploitation of the public domain created broad public concern that the rate of exploitation, if left unchecked, would rapidly deplete the nation’s resource base.”).

[57] Act of Mar. 3, 1891, ch. 561, 26 Stat. 1095, repealed by Federal Land Policy and Management Act of 1976, Pub. L. No. 94-579, 90 Stat. 2743.

[58] Forest Service Organic Administration Act of 1897, ch. 2, 30 Stat. 11, 34–36 (codified as amended at 16 U.S.C. §§ 473–482, 551 (2006)).

[59] See Hardt, supra note 51, at 353–55.

[60] See id. at 355–58 (quoting Gifford Pinchot, Breaking New Ground 261 (commemorative ed., Island Press 1998) (1947)).

[61] 16 U.S.C. §§ 528–531 (2006).

[62] Hardt, supra note 51, at 351 (noting that the limited multiple use policies of the late 1800s have changed in two major ways: 1) “multiple use” has expanded to cover more uses, such as recreation and aesthetic uses, and 2) requirements have been introduced for comprehensive management and noncommodity use management).

[63] Jan G. Laitos & Thomas A. Carr, The Transformation on Public Lands, 26 Ecology L.Q. 140, 149–50 (1999) (“During the heyday of the multiple-use management era (1930–1970), commodity uses of federal lands were dominant. In the 1970s, however, new environmental laws (triggered by a burgeoning environmental movement) led to growing restrictions on the traditional extractive uses of public lands.” (footnote omitted)).

[64] Haeuber, supra note 50, at 4 (“Regional scale resource management approaches have been evident in the United states for quite some time. For example, the Great Lakes Water Quality Agreement, signed in 1972 and revised in 1978, established the principles and process for a functioning regional [ecosystem management] approach. Similarly, land and resource managers in the Greater Yellowstone Ecosystem region have experimented with elements of an [ecosystem management] approach for nearly 30 years, beginning with establishment of the Greater Yellowstone Coordinating Committee in the early 1960s.” (footnote omitted)).

[65] J.B. Ruhl, Ecosystem Management, the ESA, and the Seven Degrees of Relevance, 14 Nat. Resources & Env’t 156, 157 (2000) (“Threads of scientific research and commentary consistent with the ecosystem management theme extend back well into the 1980s, but until the early 1990s writers did not routinely use the phrase ‘ecosystem management’ as a term of art with which readers were generally expected to be familiar.”).

[66] Keiter, supra note 48, at 44 (“[F]ederal land management officials are beginning to take initial, cautious steps to design meaningful transboundary management programs that protect shared ecosystems . . . .”).

[67] National Environmental Policy Act of 1969, 42 U.S.C. §§ 4321–4307f (2006).

[68] Keiter, supra note 48, at 44–45 (concluding that NEPA does not “impose[] a legal obligation on federal land managers to protect shared ecosystem resources,” but also concluding that “as a procedural matter,” NEPA “compels land managers to view their actions from an ecological perspective, even if it does not require them to adopt the most ecologically sensitive course of action”).

[69] Id. at 48 (“[W]hile NEPA insures ‘process’ coordination among neighboring federal land management agencies, it does not insure meaningful substantive coordination sensitive to transboundary ecological realities. Nonetheless, the courts have proven particularly sensitive to interagency disagreements or disputes when reviewing NEPA claims.”); see also Robertson v. Methow Valley Citizens Council, 490 U.S. 332, 353 (1989).

[70] See Keiter, supra note 48, at 51 (“In sum, NEPA contemplates that serial development proposals will be analyzed aggregately at the outset and not after the agency has committed itself to a course of action.”).

[71] See id. at 51–52.

[72] See Hardt, supra note 51, at 393 (“Forest Service regulations currently direct that regional and forest plans be based upon the ‘[r]ecognition that the National Forests are ecosystems and their management for goods and services requires an awareness and consideration of the interrelationships among plants, animals, soil, water, air, and other environmental factors within such ecosystems.’” (alteration in original) (quoting 36 C.F.R. § 219.1(b)(3) (1992))).

[73] Haeuber, supra note 50, at 2 (“Ecosystem management . . . is a prominent recent policy alternative proposed to address this new generation of issues. At least 18 federal agencies currently are exploring the concept of ecosystem management and its implications for their activities. Each of the major land and natural resource management agencies has drafted policy guidance regarding ecosystem management approaches.” (footnote omitted)).

[74] Yaffee et al., supra note 55, at xvi (stating, in addition to cataloging 105 ecosystem management efforts in the United States and analyzing the available results, that “[t]he intensity of the debate over ecosystem management at times has hidden a simple reality: People on the ground . . . are already actively engaging in ecosystem management experiments. . . . Few are managing at the ecosystem scale, but most are taking an ecosystem approach to
resource management”).

[75] See Haeuber, supra note 50, at 23 (“As currently developing, [ecosystem management] is a spontaneous manifestation of local level concerns, needs and desires for the future. It is less rational planning than an ‘organic’ process characterized by mutation and natural selection of solutions that develop and evolve at different rates and in diverse ways in many areas around the country.”).

[76] Yaffee et al., supra note 55, at 40 (“Since much of the rhetoric associated with ecosystem management in recent years has come from federal officials, it was surprising to discover how much activity is under way at the state level. State agencies are being innovative. . . . Several states are attempting to use ecosystem management as a philosophy underlying their overall approach to resource management.”).

[77] See Hardt, supra note 51, at 392–93 (“To render federal land use decisions within an ecosystem management framework, multiple use decisions should proceed simultaneously at two levels. First, based upon a complete inventory of current environmental conditions and natural resources, federal land managers should apply known ecological principles to establish the maximum level of disturbance that can be allowed within the management area without destroying the viability of the ecosystem. Second, an interdisciplinary team of land managers should, through federal land planning processes and based upon public input, determine the appropriate mix of uses that will be allowed within the ecosystem viability ceiling. While the ecosystem viability ceiling should be a nonpolitical, scientific determination, the second decisionmaking stage, which might be called the ‘lifestyle prong,’ clearly requires political decisions based upon public preferences . . . . It is critical, however, that the lifestyle decision not override the ecosystem viability determination and that short-term lifestyle decisions not cause long-term ecological damage.”).

[78] Id. at 391–96 (concluding that the principle of “[m]aintaining [v]iable [e]cosystems” should govern when evaluating public lands policies between multiple potential uses). “Only by maintaining the health of this country’s ecosystems can federal land managers ensure that they are providing the greatest good for the greatest number over the long run.” Id. at 391.

[79] Keiter, supra note 48, at 50 (“Meaningful ecosystem-based management must be concerned with the cumulative regional impacts accompanying federal land and resource management decisions. Most resource management decisions inevitably cause environmental impacts that reach beyond established boundaries, affecting adjacent and sometimes distant lands, usually through common resource systems.”).

[80] Hardt, supra note 51, at 394–95 (“Defining the appropriate ecological area over which management decisions should be made is complex. . . . Consequently, in defining a management area, the objective should be to establish ‘administrative ecosystems’ so that the primary energy and nutrient links within a given biological community are managed comprehensively. Several commentators have suggested that watersheds should define ecologically based management areas.” (footnote omitted)).

[81] See Haeuber, supra note 50, at 5–6; Yaffee et al., supra note 55, at xv (“[T]he dialogue often has bogged down in arguments over ‘just what is ecosystem management’ and ‘what are its goals.’”).

[82] Yaffee et al., supra note 55, at 44 (“[E]cosystem management is not management toward any end. Rather, it seeks to protect and restore the ecological integrity of landscapes while building sustainable economies and effective organizational and decision-making structures.”).

[83] Id. at xii–xiii (noting funding problems as significant hurdles in the way of cooperative ecosystem management efforts).

[84] Lee P. Breckenridge, Nonprofit Environmental Organizations and the Restructuring of Institutions for Ecosystem Management, 25 Ecology L.Q. 692, 693 (1999) (noting that while “nonprofit organizations may often provide important transformative frameworks” toward ecosystem management ends, “[n]ot all nonprofit organizations will work effectively to restore and maintain ecologically viable natural systems, . . . and the increasing reliance on nonprofit organizations raises important issues concerning institutional design and accountability”).

[85] See Allan K. Fitzsimmons, Defending Illusions: Federal Protection of Ecosystems 34–39 (1999) (“Using ecosystems as a geographic basis for government authority, therefore, represents a radical departure from our national experience with establishing the spatial boundaries guiding the application of government power.”).

[86] See id. at 46–48 (stating that among the “geographic fraternity[,] . . . most reject the idea that regions are actual objects on the landscape”); id. at 48–56 (noting that climate, vegetation, and soil are all problematic bases for mapping ecosystems).

[87] See id. at 240–43 (“Only through national land use planning and management can the federal government ensure that the public obtain newly fabricated rights to ecosystem integrity . . . . The notion that a Washington bureaucracy can rationally plan or direct land use decision making to achieve . . . ‘optimal land use decisions’ rests on a false assumption and posits in government a wisdom and an ability that neither our government nor any others have ever demonstrated. . . . What evidence is available that a Washington bureaucracy is capable of either making or guiding intelligent land use decisions for the nation? The total amount of knowledge and information that people use in making such decisions is beyond calculation. . . . People make land use decisions that reflect constantly changing economic, social, and environmental circumstances. Their judgments factor in new developments in science, technology, and other ingredients that contribute to the functioning of society. Decisions reflect individual choices and ideas about how to better the lives of those making them. How is it possible for a central authority to accumulate all the knowledge and data needed to make sound land use decisions, much less comprehend what it collects? How can a bureaucracy sort out the needs of tens of millions of individuals and tens of thousands of communities and make benevolent land use decisions on that basis? Because of the enormity and complexity of the task, they could not do so even if they wanted to. Ultimately, the planners’ decisions would be driven by the political signals they receive from the interests that keep them in power and by their own desires to expand their programs and budgets rather than by the views of the public from which they would be isolated and to which they would be accountable.” (footnote omitted)).

[88] Haeuber, supra note 50, at 5–7.

[89] Id. at 7.

[90] Yaffee et al., supra note 55, at xii–xiii (“Natural resource managers, project coordinators, and decision makers on the ground are struggling against imposing odds to make land management work. They have little direction and often face incredible political or administrative hurdles.”).

[91] Id. at 41 (“By requiring more collaborative work from diverse stakeholders with often conflicting interests, ecosystem-based approaches to land management run head-on into the problems commonly associated with human relations and group decision making. . . . Many current policies make it difficult to practice effective ecosystem management. Participation in numerous land management planning processes initiated by different federal and state agencies consumes the limited time and resources available to nongovernmental stakeholders. Multiple, independent planning processes often make it difficult to take a larger-scale perspective.”).

[92] Id. at 33 (“Problems associated with agencies were reported by 31 percent of the respondents, with the largest portion describing institutional obstacles including a lack of interagency coordination and cooperation and administrative red tape. In many cases, these issues were unavoidable given the need to involve all affected stakeholders and the resulting complexities of multiple decision making layers . . . . [J]urisdictional conflicts between agencies were the source of several problems, despite the good intentions of individuals within those agencies or of project coordinators.”).

[93] Laitos & Carr, supra note 63, at 218–20 (concluding that “the promise of ecosystem management as a long-term public land management strategy is problematic” for many reasons: 1) the inherent difficulty in defining “ecosystem management,” 2) the tension between “biocentric” and “anthropocentric” policy goals, 3) establishing ecosystem boundaries,
4) insufficient data, and 5) coordination problems “among all interested parties—federal, state, and private”). On the other hand, one commentator has concluded that all levels of government—local, state, and federal—are mismatched with respect to the scale of ecosystem management projects, either being underinclusive or overinclusive with respect to any particular ecosystem, and that ecosystem-based management efforts are therefore the proper solution. Bradley C. Karkkainen, Collaborative Ecosystem Governance: Scale, Complexity, and Dynamism, 21 Va. Envtl. L.J. 189, 212–17 (2002) (arguing that, with respect to “the demands of ecosystem management,” governments at all levels of hierarchy are mismatched: Local governments are underinclusive, requiring coordination “at a larger geographic scale,” and lack resources and expertise; state governments are sometimes underinclusive and sometimes overinclusive, depending upon the state; and the federal government “is almost certainly too big and too remote from the highly variable, locally situated, complex interdependencies that comprise ecosystems to assume sole or even principle responsibility for managing them”). Under this view, presumably, ecosystem management should therefore go forward despite the hardships, as the most feasible alternative.

[94] Yaffee et al., supra note 55, at 23 (“While one-third of the projects reported specific ecological results, the five outcomes cited most frequently can be viewed as procedural in nature.”). The five most frequently cited outcomes were 1) improved communication and cooperation (74%), 2) development of management plan (62%), 3) development of decision-making structures (56%), 4) change in approach to land management (50%), and 5) ongoing restoration activities (46%). Id. at 23 fig.13.

[95] George Cameron Coggins, Watershed as a Public Natural Resource on the Federal Lands, 11 Va. Envtl. L.J. 1, 13–14 (1991) (noting that protection of watershed resources necessarily involves three considerations: 1) maintenance of instream flow, 2) protection of the riparian zone near streams, and 3) protection of the uplands beyond the riparian zone, which affects the largest area of land).

[96] Comm. on Watershed Mgmt., Nat’l Research Council, New Strategies for America’s Watersheds, at ix (1999) (“[W]atersheds are logical divisions or regions of the natural landscape, and for some purposes they are ultimately the best framework to use for management.”); Coggins, supra note 95, at 45 (“[I]t is logically inescapable that watershed is the key, integrative public resource.”); id. at 44 (“All resource uses are dependent on the system in which water and watershed values are integral parts.”).

[97] Coggins, supra note 95, at 13 (“Literally, watershed is the area drained by a river or river system, including riparian zones and uplands.” (footnote omitted)).

[98] Id. at 44 (“Although the term watershed technically denotes a geographic area, in congressional contemplation it more resembles an entire system with multiple productive capabilities. The system has soil, water, vegetative and other biotic components, all of which interact to stabilize, maintain and enhance each other and the system itself. Without water, the other components will suffer and die.”).

[99] J.A. Stanford & J.V. Ward, Management of Aquatic Resources in Large Catchments: Recognizing Interactions Between Ecosystem Connectivity and Environmental Disturbance, in Watershed Management: Balancing Sustainability and Environmental Change 91, 93 (Robert J. Naiman ed., 2002) [hereinafter Watershed Management] (“In the United States, the term watershed is often misused in the context of river basin research and management. By proper definition, the watershed is the ridgeline or elevation contour that delimits drainage basins or catchments. The catchment is bounded by the watershed, and since water flows downstream from the watershed through the catchment, thereby integrating influences of natural and human disturbances within the catchment, we use the watershed as the natural ecosystem boundary.”).

[100] William Goldfarb, Watershed Management: Slogan or Solution?, 21 B.C. Envtl. Aff. L. Rev. 483, 483 (1994) (“The trend toward watershed management is a response to the following fundamental legal-institutional problems of water resources management: A) Transboundary water management problems; B) Implications of federalism and separation of powers; and C) Variability of water law among political units.”).

[101] Bob Doppelt et al., Entering the Watershed: A New Approach to Save America’s River Ecosystems 18–23 (1993) (listing dangers to watershed ecosystems such as logging, transportation infrastructure, grazing, mining, urbanization, point and nonpoint pollution, overharvest, and introduction of exotic species); Coggins, supra note 95, at 19–21 (citing timber harvesting, associated road building, extensive grazing, mining, mineral leasing, water diversions, and intensive motorized recreation as threats to watershed quality).

[102] Doppelt et al., supra note 101, at xxv–xxvi (“Watersheds are ecosystems composed of a mosaic of different land or terrestrial ‘patches’ that are connected by (drained by) a network of streams. In turn, the flowing water environment is composed of a mosaic of habitats in which materials and energy are transferred and, therefore, connected through biologically diverse food webs. Human activities can result in the fragmentation and disconnection of the habitat patches if management is not planned and implemented from an ecosystem and watershed perspective.”).

[103] See Jon Cannon, Choices and Institutions in Watershed Management, 25 Wm. & Mary Envtl. L. & Pol’y Rev. 379, 391 (2000).

[104] Id. (“In the late nineteenth century, John Wesley Powell advocated that settlement in the arid west be organized within ‘“hydrographic basins,” or watershed units . . . rather than by the prevailing township and county system.’ Reflecting the dominant values of his time, Powell’s proposal was designed to facilitate publicly controlled development of water resources for irrigation . . . [,] not to protect the ecological health of aquatic systems.” (first alteration in original) (quoting Donald Worster, Rivers of Empire 138 (1941))).

[105] Timber Culture Act of 1873, ch. 277, 17 Stat. 605 (1873) (repealed 1891); see Coggins, supra note 95, at 4.

[106] See Coggins, supra note 95, at 4.

[107] 16 U.S.C. §§ 473–478, 551 (2006).

[108] Id. § 475; see Coggins, supra note 95, at 4–5. By “water flows,” Congress meant “watersheds.” Id.

[109] 438 U.S. 696 (1978).

[110] See id. at 712–13; Coggins, supra note 95, at 5.

[111] Goldfarb, supra note 100, at 486 (“Watershed management’s closest antecedent is the concept of ‘unified river basin management,’ which has been influential in the water resources management community since approximately 1900.”).

[112] Id. at 486–87.

[113] Id. (noting that, of the three periods in “the evolution of unified river basin management,” the first period, 1900–1933, was characterized by “[m]ultipurpose, basinwide water resources development” that was oriented toward “flood control, municipal water supply, irrigation, hydroelectric power generation, recreation, and water quality improvement”).

[114] Adler, supra note 6, at 1005 (“[M]assive federal spending on large, structural water projects to optimize and ‘manage’ the use and value of water for human benefits [is] reflected in laws such as the Reclamation Act of 1902, the Federal Power Act of 1920, and the Flood Control Act of 1936.” (footnotes omitted)).

[115] Id. at 1005–06 (“The idea of integrated river basin water policy was developed during the Progressive Era in a series of reports issued by various commissions under Theodore Roosevelt’s Administration: the 1908 Inland Waterways Commission, the 1909 National Conservation Commission, the 1912 National Waterways Commission, and the authorized but never formed 1917 Newlands Commission. All proposed many of the same elements present in today’s watershed proposals, such as coordination of the goals and functions of federal water agencies, comprehensive water quality and quantity planning, . . . and comprehensive evaluation of all issues from a basinwide perspective.” (footnote omitted)). These watershed proposals—never adopted—were directed by multiple-use concerns. See id. at 1006.

[116] Goldfarb, supra note 100, at 486–87 (noting that, of the three periods in “the evolution of unified river basin management,” the second period, 1933–1965, was characterized by “regional socioeconomic development through publicly-owned hydropower”).

[117] Adler, supra note 6, at 1007–08 (“A broader view of comprehensive river basin planning returned during the New Deal, in proposals by the National Planning Board, the Water Resources Committee of the National Resources Commission . . . , and the National Resources Planning Board . . . . As with Progressive Era proposals, the New Deal agencies suggested a ‘comprehensive approach integrating all resources into a unified, balanced program’ . . . . These proposals resembled today’s watershed proposals somewhat more closely than Progressive Era versions with their increased recognition of the link between land development (including deforestation) and water resources degradation caused by increased erosion and runoff.” (footnotes omitted) (quoting Norman Wengert, A Critical Review of the River Basin as a Focus for Resource Planning, Development, and Management, in Unified River Basin Management 9, 12 (Ronald M. North et al. eds., 1981))). However, these proposals—again, aside from the Tennessee Valley Authority, never adopted—were “fundamentally rooted in human use of water and economic development.” Id. at 1008.

[118] Id. at 1008–09 (“[T]he continued promotion of river basin planning by the Truman and Eisenhower Administrations . . . . resulted in the Hoover Commission proposal in 1949 to combine most federal water programs into a single cabinet-level department; Truman’s 1950 Water Resources Policy Commission report, which proposed joint federal-state river basin commissions to address both water quality and quantity planning and management; and Eisenhower’s Presidential Advisory Commission on Water Resources Policy, which . . . proposed independent project review through plans prepared by basin-level committees. . . . These proposals mirrored their predecessors’ focus on river basins and basin drainage areas as logical planning entities, but continued as well the underlying purpose of basin planning—to promote the development of water projects.” (footnotes omitted)). None of these proposals were adopted. Id. at 1009.

[119] 42 U.S.C. §§ 1962–1962d (2000); see also Goldfarb, supra note 100, at 486–87 (noting that, of the three periods in “the evolution of unified river basin management,” the third period,
1965–1990, was characterized by the rise and fall of the federal Water Resources Council as a mechanism for supervising and implementing cross-jurisdictional river basin development plans).

[120] Adler, supra note 6, at 1009 (describing the WRPA as coming from “Congress and both a republican and a democratic President”). This Act, while mentioning conservation of water and related land resources, “focused primarily on optimum water resource use and development, with only passing mention of conservation or protection.” Id. at 1011. The WRPA (as well as the Water Resources Council and River Basin Commissions created by its titles I and II, respectively) failed, arguably due to its express declining of “any impact on existing federal, state, or interstate laws, compacts, or other authorities, regardless of consistency with the goals of [the WRPA] or the outputs of the planning process.” Id. at 1011–12.

[121] Id. at 1013 (noting that, before its demise, the Water Resources Council under the WRPA issued a report whose findings included that “the development, management, and protection of water resources should be controlled by the level of government closest to the problem and most capable of representing the interests involved”).

[122] Coggins, supra note 95, at 17 (“Watershed is a coequal multiple surface use, to be managed for sustained yield, under the 1960 Multiple-Use, Sustained-Yield Act and [the Federal Land Policy and Management Act].” (footnote omitted)); see also Multiple-Use Sustained-Yield Act of 1960, 16 U.S.C. § 528 (2006); Federal Land Policy and Management Act of 1976,
43 U.S.C. § 1732 (2006).

[123] Coggins, supra note 95, at 18 (“Theoretically, all multiple use management decisions should be premised on coordinated consideration of the effects of the proposed action on all resources. Watershed should be the key element in such consideration, because all other uses ultimately depend on the quality, quantity, and stability of the soil and water—the essence of the watershed resource.” (footnote omitted)).

[124] Id. at 45–46. (“Watershed management should entail consideration of all resources and values of the federal lands and the relationships between them. . . . Many if not most federal land managers long have realized that the proper focus of multiple use, sustained yield management should not be on mineral claims, campgrounds, timber contracts, or other isolated management functions, but rather on the overall health of the land that generates such human benefits. Watershed should be viewed as the embodiment of that ‘health’ concept.”).

[125] Adler, supra note 6, at 991 (“It is difficult to imagine a political and institutional system as complicated and fragmented as that used for protecting and managing water resources in the United States—a system that has been described as ‘similar to a marbled cake, with several levels of government intermingled in an irregular pattern.’ . . . Thus, several institutional imperatives support the need for watershed-based approaches[,] . . . [including] political fragmentation—the overlapping and conflicting division of responsibilities among multiple levels of government and agencies.” (footnote omitted) (quoting William Whipple, Jr., Future Direction for Water Resources, in Water Management in the 21st Century 9, 10 (A. Ivan Johnson & Warren Viessman, Jr. eds., 1989))).

[126] Robert J. Naiman, New Perspectives for Watershed Management: Balancing Long-Term Sustainability with Cumulative Environmental Change, in Watershed Management, supra note 99, at 3, 6 (“Watershed issues require coordination on a scale seldom achieved in human societies. . . . This level of concentration on a single goal demands that socioeconomic and political barriers be crossed efficiently and effectively.”).

[127] Stanford & Ward, supra note 99, at 114–15 (“Local and regional fragmentation of management authority is guaranteed to result in interference management . . . . If human disturbances are to be managed for the purpose of maintaining natural ecological connectivity at the catchment scale, management agencies must cooperate to minimize interferences.”).

[128] Doppelt et al., supra note 101, at xxx–xxxii (calling for a range of federal activity—including consolidation of federal policy-making authority, “[e]cosystem and watershed-level planning by all federal agencies,” and “ecosystem-based watershed protection program[s] for all federal land-management agencies”—as necessary “[t]o implement the new protection and restoration approach”).

[129] Id. at 34 (calling for “the active participation of local communities in implementing” comprehensive watershed protection and restoration).

[130] See id. at 62–63 (“[S]uccessful watershed restoration programs require the active involvement and support of local communities and citizens. . . . Most of the daily decisions that affect riverine systems are made at the local level. It is the local communities that are most directly harmed by degraded riverine conditions . . . , and it is the local communities that will be asked to give up the most perceived economic gain to protect and restore a river. . . . Hence, local communities must be actively engaged in bottom-up efforts to restore riverine systems and biodiversity. . . . [F]or citizens to take charge of their own destiny and to be willing to forgo perceived economic gains requires something more than just desire. It requires empowerment, effective new incentives, the removal of disincentives, [and] effective implementation structures.”).

[131] See Adler, supra note 6, at 1091 (“[T]he largest watershed units, probably at the basinwide scale, should address issues of regional planning, assessment, and coordination, to ensure that the program properly acknowledges and addresses regional impacts and connections, and to establish the broadest level of regional goals and objectives.”
(footnote omitted)).

[132] Id. at 1104 (“[T]here remains the question of federal consistency with state and regional watershed programs and requirements. . . . Yet many past consistency provisions have been weak or equivocal, giving discretion to federal agencies to avoid state or regional requirements. . . . [T]here is no reason why, once states and regions adopt watershed protection requirements designed to meet national as well as regional aquatic ecosystem restoration and protection goals, federal activities should not be subject to those requirements in full.” (footnote omitted)).

[133] Comm. on Watershed Mgmt., supra note 96, at 2 (“The environmental, social, and economic diversity of the United States dictates that one standard solution is unlikely to be useful in all parts of the country. . . . Any well-designed national policy for watershed management must maintain great flexibility to accommodate these natural and human variations and allow significant local control and input to decisions.”).

[134] Id. at 3–4 (“Organizations for watershed management are most likely to be effective if their structure matches the scale of the problem. . . . A major barrier to effective watershed management for large basins in the past has been limitations on the transfer of powers. The various levels of government in the United States developed historically with specific authorities and powers, and most governmental entities are unlikely to give up those powers to some larger all-encompassing organization. . . . Partnerships among levels of government and various agencies are required for effective watershed management. The era of a large, dominant federal government must give way to an era of flexible federalism where the federal government maintains a role but allows state and local governments to assume substantial rights and responsibilities for watershed management.”).

[135] Id. at 204 (“The historical development of governmental organizations in the United States dictates a certain distribution of powers among levels and among agencies within the same level. Watershed management through newly defined organizations will not succeed unless there is a transfer of powers from those established agencies, often an unlikely scenario. Therefore, watershed management in the United States is often best accomplished through partnerships of existing agencies that work together in ad hoc arrangements for
particular watersheds.”).

[136] Coggins, supra note 95, at 10 (“The most basic definitional problem raised by the [watershed-related] statutes is whether the aim of watershed resource management should be production or protection, or both.”).

[137] Goldfarb, supra note 100, at 484–85 (“Regional solutions to water resources management problems are also frustrated by the difficulty of defining a water resources problem-shed in a way that will both promote holistic problem-solving and elicit political support. . . . The arduous political task of regional institution-building is further exacerbated by [the Environmental Protection Agency’s] strategy of adopting an ad hoc, esoteric definition of ‘watershed.’”).

[138] Adler, supra note 6, at 1093–94 (“[N]o agreement yet exists on a single framework for environmental boundaries. Hydrological purists continue to advocate programs based on watershed boundaries, while aquatic ecologists now suggest that watershed ecosystems reflect more accurate ecological boundaries. But ecological boundaries often cannot be identified with precision . . . . There is probably no single answer to this paradox, as is illustrated by the fact that no single ecosystem delineation is more ‘correct’ than others.” (footnote omitted)).

[139] Id. at 1095 (“When aquatic ecosystems cross so many state and international boundaries, a strong federal presence is essential to ensure that progress and goals are reasonably equal around the country. Yet uniform federal regulation of land use will continue attracting significant opposition, and is not appropriate in all cases.”); id. at 1102 (“Historical precedent, along with increasing opposition to anything federal in scope or origin, tends to suggest that watershed programs should be voluntary and flexible. Previous efforts to establish a nation-wide system of watershed management failed, in part due to strong resistance to mandatory federal programs in the areas of land and water use and also to perceived federal control over these domains.”).

[140] Comm. on Watershed Mgmt., supra note 96, at 10–11 (noting that a recurrent theme appearing “throughout the committee’s deliberations” was that “fragmentation of responsibility and lack of clarity about how to resolve disputes caused by conflicting missions among federal agencies inhibits the success of the watershed approach” ).

[141] Goldfarb, supra note 100, at 484 (“American political boundaries do not, for the most part, correspond to water resources problem-sheds. Most water resources problems are transboundary in nature, i.e., intermunicipal, interstate, or international. In the American political system, regional political institutions are difficult to create and, when established, tend to lack political viability. Thus, there is rarely a single competent institution with legal jurisdiction over a water resources problem of regional dimension.” (footnotes omitted)).

[142] Id. (“In addition, water resources problems such as interbasin transfers of water transcend even recognized regional boundaries. This institutional situation creates the traditional incentive for one jurisdiction to solve its own development problems without regard to spillover water resources effects on neighboring jurisdictions . . . . In this process of cost externalization, tragedies of the commons are often overlooked.”).

[143] Id. at 485 (“Myriad governmental institutions at the international, federal, interstate, state, substate regional, and local levels of government play significant roles in managing water resources. Institutional rivalries, conflicting or overlapping jurisdictions, diverse constituencies, and other factors cause frequent disagreements among these institutions with regard to water resources issues.”).

[144] Id. at 498 (“Problem-based regions may be conterminous with the problems to be solved, but such regions themselves raise institutional difficulties: 1) the larger the region, the more institutions and interest groups must be included in problem-solving, thus intensifying institutional conflicts and political rivalries; and 2) the larger the region, the greater is the possibility that only the federal government, which may be far removed from the problem area and lack political credibility there, will be capable of devising and imposing a solution.”).

[145] See Doppelt et al., supra note 101, at 59 (“Effective watershed restoration also requires greatly improved system-wide policy coordination and consistency. On many rivers, 30 to 40 public agencies have programs entrained that affect the watershed. Each agency has different legislatively established missions and goals. . . . These interests fail to communicate with one another, and their activities and policies are almost never coordinated so that the integrity of the riverine system is maintained. New mechanisms are needed to move beyond the piecemeal management pattern evident on every riverine system nationwide so that systemwide planning, coordination and consistency can be realized.”).

[146] Comm. on Watershed Mgmt., supra note 96, at 5 (“Watersheds as geographic areas are optimal organizing units for dealing with the management of water and closely related resources, but the natural boundaries of watersheds rarely coincide with political jurisdictions and thus they are less useful for political, institutional, and funding purposes.”).

[147] Adler, supra note 6, at 991–92 (“[W]ater resource programs logically should be organized according to watershed boundaries. Politically, however, this has been difficult because each level of government guards its authority jealously. Instead, control over water resources is divided between federal, state, and local governments.” (footnote omitted)).

[148] Id. at 1088–89 (“[W]atershed programs should proceed at the scale of whole river basins or other broadly defined hydrological regions . . . . Watershed programs of broad regional scale, however, face significant political and institutional problems. Large watersheds usually cross more political boundaries (local, state, or national), resulting in greater need for intergovernmental coordination. . . . [E]ach new player complicates institutional and political problems and increases the possibility of turf battles, conflicting goals and values, and other parochial behavior. Problems range from the logistical challenge of coordinating a large number of governmental and nongovernmental entities, to the more fundamental difficulty of identifying and accommodating the needs of many regional interests, including diverse social, economic, and environmental interests.” (footnotes omitted)).

[149] Id. at 1103 (“[S]ome standardization would help avoid the very confusion, gaps, and conflicts that [voluntary] watershed programs are designed to address. Disparate watershed programs around the country likely would adopt divergent approaches to the issues of scale, boundary, mission, and control addressed above. Programs could overlap, conflict, or seek conflicting goals. Inefficiencies could occur due to overlapping jurisdictions, and individual programs would lose economies of scale. While flexibility is desirable to foster creative solutions appropriate to individual sites, management anarchy can be counterproductive.”).

[150] Peter P. Swire, The Race to Laxity and the Race to Undesirability: Explaining Failures in Competition Among Jurisdictions in Environmental Law, 14 Yale L. & Pol’y Rev. (Symposium Issue) 67, 80, 106 (1996) (“Understanding the Race to the Bottom and NIMBY in this way helps us understand important patterns in local environmental decisions, where people’s ‘back yards’ are especially noticeable. Either the Race to the Bottom or NIMBY, or both, might occur in a particular setting. Where the benefits of development are salient—with visible and concentrated benefits to industry and politicians—then public choice effects tend toward laxity. Where the costs of development are salient—with visible and concentrated costs on neighbors and consequent effects on politicians—then public choice effects tend toward strictness.”).

[151] Larry Kramer, Understanding Federalism, 47 Vand. L. Rev. 1485, 1499 (1994) (“[S]tate regulation is sometimes justified on the ground that it encourages regulatory innovation, the idea being that state and local governments have incentives to experiment with regulatory policy to attract capital and taxpayers—acting, in Justice Brandeis’ famous phrase, as ‘laboratories’ of democracy.” (citing New State Ice Co. v. Liebmann, 285 U.S. 262, 311 (1932) (Brandeis, J., dissenting))).

[152] See Sale, supra note 19, at 42 (emphasis added).

[153] See id. at 57 (“A watershed—the flows and valleys of a major river system—is a particularly distinctive kind of georegion, more easily mapped than most . . . .”).

[154] U.S. Const. art. IV, § 3, cl. 1.

[155] Id. art. I, § 2, cl. 1.

[156] See id. amend. XVII, cl. 1 (“The Senate of the United States shall be composed of two Senators from each State, elected by the people thereof . . . .”).

[157] Id. art. III, § 1.

[158] Id. art. V (“The Congress . . . shall propose Amendments to this Constitution, or, on the Application of the Legislatures of two thirds of the several States, shall call a Convention for proposing Amendments, which, in either Case, shall be valid to all Intents and Purposes, as Part of this Constitution, when ratified by the Legislatures of three fourths of the several States, or by Conventions in three fourths thereof, as the one or the other Mode of Ratification may be proposed by the Congress; Provided . . . that no State, without its Consent, shall be deprived of its equal Suffrage in the Senate.”).

[159] See id. art. I, § 2, cl. 1; id. art. I, § 3, cl. 1; id. art. II, § 1, cl. 2 (delegating representatives, senators, and electors on a state-by-state basis).

[160] See, e.g., Or. State Archive, Oregon State Bluebook: State Government, http://bluebook.state.or.us/state/index.htm (last visited Apr. 18, 2010) (explaining the branches of the Oregon state government, as well as their functions and powers).

[161] See generally U.S. Const. arts. I–III.

[162] 369 U.S. 186 (1962).

[163] Id. at 218–25 (“We shall discover that Guaranty Clause claims involve those elements which define a ‘political question,’ and for that reason and no other, they are nonjusticiable. In particular, we shall discover that the nonjusticiability of such claims has nothing to do with their touching upon matters of state governmental organization.”).

[164] 48 U.S. (7 How.) 1 (1849).

[165] See Baker, 369 U.S. at 220 (“Under this article of the Constitution it rests with Congress to decide what government is the established one in a State. For as the United States guarantee to each State a republican government, Congress must necessarily decide what government is established in the State before it can determine whether it is republican or not. And when the senators and representatives of a State are admitted into the councils of the Union, the authority of the government under which they are appointed, as well as its republican character, is recognized by the proper constitutional authority. And its decision is binding on every other department of the government, and could not be questioned in a judicial tribunal.” (internal quotation marks omitted) (quoting Luther, 48 U.S. at 42)).

[166] 88 U.S. (21 Wall.) 162 (1874).

[167] See Baker, 369 U.S. at 222–23 n.48 (“The guaranty is of a republican form of government. No particular government is designated as republican, neither is the exact form to be guaranteed, in any manner especially designated. Here, as in other parts of the instrument, we are compelled to resort elsewhere to ascertain what was intended. The guaranty necessarily implies a duty on the part of the States themselves to provide such a government. All the States had governments when the Constitution was adopted. In all the people participated to some extent, through their representatives elected in the manner specially provided. These governments the Constitution did not change. They were accepted precisely as they were, and it is, therefore, to be presumed that they were such as it was the duty of the States to provide. Thus we have unmistakable evidence of what was republican in form, within the meaning of that term as employed in the Constitution.” (internal quotation marks omitted) (quoting Minor, 88 U.S. at 175–76)).

[168] See U.S. Const. art. IV, § 3, cl. 1.

[169] See id.

[170] See Sale, supra note 19, at 91 (“The ecological law with which bioregional politics would logically begin is decentralism, centrifugal force, the spreading of power to small and widely dispersed units.”).

[171] See id. at 94–95.

[172] U.S. Const. art. I, § 6, cl. 2.

[173] U.S. Geological Survey, U.S. Dep’t of the Interior, National Atlas of the United States of America: Rivers and Lakes (2003), available at http://www-atlas.usgs.gov/printable/
images/pdf/outline/rivers_lakes.pdf.

[174] U.S. Const. art. III, § 2, cl. 1.

[175] See Charles W. Watson, Recent Cases, Environmental Law—Cause of Action Under Federal Common Law for Pollution of Interstate Waters, 77 Dick. L. Rev. 451, 454–56 (1972) (“Mr. Justice Douglas . . . held [in Illinois v. City of Milwaukee, 406 U.S. 91 (1972),] that federal common law controls the pollution of interstate waters. . . . Mr. Justice Douglas held that the legislative efforts [to] reduce the pollution of interstate waters and the express declaration of the federal policy of protecting the rights of the states to control pollution had established a right in an aggrieved state to abate a public environmental nuisance under the federal common law. . . . The federal common law as fashioned by the federal district courts will replace the various state laws in the area of interstate water pollution. Although the federal judges are to act largely on their own ‘informed judgments,’ uniformity is established in the sense that all actions brought in the district courts will be resolved according to the same body of federal common law . . . . The Supreme Court has long recognized that it possessed the jurisdiction to adjudicate the equitable rights of states in common waters. In addition, a state may enjoin another state from using common waters so as to create a nuisance to the citizens of the aggrieved state.” (footnotes omitted)).

[176] Amendment 1 describes a two-state method for boundary redrawing as severed from any general boundary-redrawing method and includes time limits for the redrawing process, restrictions on the negotiating parties to prevent conflicts of interest, the drawing of bioregionally oriented state boundaries on the basis of watersheds or bisected watersheds, the fair-division mechanism presented to the two states, and periods of time before the results of the negotiation are given effect.

[177] Amendment 2 describes a general boundary-redrawing method as coordinating an iterated series of two-state, boundary-redrawing negotiations as described in Amendment 1 and includes congressional ordering of boundary redrawing and setting of boundary-redrawing timelines, as well as provisions for boundaries not tractably redrawable by negotiation between States-in-Waiting.

[178] Amendment 3 describes the formation of bioregionally oriented boundaries of federal legal effect subsequent to a general boundary-redrawing method, and harmonizing bioregionally oriented federal boundaries with the bioregionally oriented state boundaries resulting from the general boundary-redrawing method.

[179] Amendment 4 describes the clarification of “Republican Form of Government” to require that boundaries within bioregionally oriented states, such as county boundaries, be themselves bioregionally oriented.

[180] Amendment 5 describes a grand bargain by which federal environmental policy must agree with environmental policy established by related bioregionally oriented states.

[181] See The Federalist No. 10, at 73–74 (James Madison) (Clinton Rossiter ed., 1961)
(“The latent causes of faction are thus sown in the nature of man; and we see them everywhere brought into different degrees of activity . . . . A zeal for different opinions concerning religion, concerning government, and many other points, as well of speculation as of practice; an attachment to different leaders ambitiously contending for pre-eminence and power; or to persons of other descriptions whose fortunes have been interesting to the human passions, have, in turn, divided mankind into parties, inflamed them with mutual animosity, and rendered them much more disposed to vex and oppress each other than to co-operate for their common good. So strong is this propensity of mankind to fall into mutual animosities, that where no substantial occasion presents itself, the most frivolous and fanciful distinctions have been sufficient to kindle their unfriendly passions and excite their most violent conflicts.”).

Brief for Natural Resources Defense Council as Amici Curiae Supporting Respondent, Monsanto Co. v. Geertson Seed Farms, No. 09-475 (U.S. Apr. 5, 2010)

By Craig Johnston*

Monsanto Co. v. Geertson Seed Farms is a case in which the Supreme Court is considering the propriety of an injunction the Ninth Circuit affirmed which precludes Monsanto from selling a form of genetically-modified alfalfa (known as Roundup Ready alfalfa or RRA) until the United States Department of Agriculture (USDA) complies with the National Environmental Policy Act (NEPA). The district court determined that the USDA, through its Animal and Plant Health Inspection Service (APHIS), had violated NEPA by failing to complete an environmental impact statement (EIS) before deregulating RRA. Neither Monsanto nor the United States appealed this aspect of the district courts opinion.

Instead, the only element of the case that is still at issue is the propriety of the district courts injunction. In seeking to overturn that injunction, Monsanto argues at the Supreme Court level, for the first time, that the sufficient likelihood of irreparable injury requirement dictates that a threatened harm, no matter how serious, must be preponderantly likely to occur before a court has the equitable power to enjoin conduct giving rise to that threat. It is this issue that Professor Johnston addresses in this brief for the Natural Resources Defense Council.

 

No. 09-475

IN THE SUPREME COURT OF THE UNITED STATES

MONSANTO COMPANY, ET AL., PETITIONER

v.

GEERTSON SEED FARMS, ET AL., RESPONDENT

On Writ Of Certiorari

To The United States Court Of Appeals

For The Ninth Circuit

 

BRIEF FOR AMICI CURIAE

NATURAL RESOURCES DEFENSE COUNCIL,

PROF. CRAIG N. JOHNSTON,

PROF. MICHAEL C. BLUMM,

PROF. DAVID W. CASE,

PROF. JAMISON E. COLBURN,

PROF. WILLIAM F. FUNK,

PROF. DAVID K. MEARS,

PROF. PATRICK A. PARENTEAU,

PROF. JOHN T. PARRY,

PROF. MELISSA A. POWERS, AND

PROF. MARY C. WOOD,

IN SUPPORT OF RESPONDENTS

 

[*Ed. note: The Table of Contents and Attorney Contact Information were omitted from this online-only version.  Please see the print version of Vol. 40, Issue 2 for the complete version] 

INTEREST OF THE AMICI CURIAE[1]

Amici curiae are a national environmental organization and ten law professors. The Natural Resources Defense Council, which has 1.2 million members and supporters, uses law and science to secure a safe and healthy environment for all living things. The amici law professors are teachers and students of environmental law, and have a longstanding interest in how the principles of equitable relief are applied in environmental cases.

The amici believe this is a case where respondents have readily met the traditional “likelihood of irreparable injury” requirement. The district court and court of appeals both expressly applied that test and found that irreparable injury was likely to occur. No good cause exists for this Court to revisit that factbound ruling. Petitioners, however, seek in their brief to inject a new legal issue, not raised below, by suggesting that the “likelihood” standard requires a rigid application of a “more likely than not” test for the probability of harm, irrespective of its potential magnitude. This case
does not provide the appropriate vehicle to consider the validity of this
newly-proffered test, not passed on by the courts below. In any event, the proposed standard is without merit. Should the Court decide to address the issue, it should therefore squarely reject the proffered standard. The sole purpose of this amicus submission is to address this issue in case the Court decides to consider it.

A further description of the amici is set forth in an Appendix to this brief.

SUMMARY OF THE ARGUMENT

It is hornbook law that courts may issue injunctions only where there is a likelihood of irreparable injury. See, e.g., Winter v. Natural Res. Def. Council, 129 S. Ct. 365, 375 (2008) (dicta), and City of Los Angeles v. Lyons, 461 U.S. 95, 111 (1983) (requiring a “sufficient likelihood” of such injury). Monsanto Co. (“Monsanto”) argues that this formulation denies courts the power to issue injunctions in response to threatened harms, no matter how serious their potential consequences, unless those harms are more than 50% likely to materialize. Brief for Monsanto (“Petr.’s Br.”) 33, 41-47. This argument wrongly assumes that the term “likelihood” connotes “more likely than not” in this context. It also ignores the basic principle that whether a threatened harm is “sufficiently likely” turns on both the probability of its occurrence and the severity of its consequences should it occur.

Monsanto’s reading of the traditional equitable test is both illogical and ahistorical. Under its approach, for example, courts would be unable to enjoin the maintenance of severe fire hazards in residential areas if the risks of conflagration were “only” 40%. Similarly, a court would be powerless even where a simple injunctive order might be all that is required to preclude a 50% chance that a lethal virus would be introduced to New York City’s
water supply.

As will be shown below, the courts of equity long have used both public and private nuisance principles to halt conduct and address conditions posing serious threats to the public weal, regardless of whether the feared harm was more likely than not to come to fruition. While at first there were not many cases, their numbers have increased over the years. Where the threats have been sufficiently serious, the courts have simply deemed the circumstances giving rise to them to be nuisances, which in turn has enabled them to issue injunctive relief where necessary to achieve equity. In case after case, the courts have applied these dynamics without requiring that the harm be preponderantly likely to occur. In effect, where faced with sufficiently serious threats of irreparable harm, courts have recognized that the threats themselves constitute a likely and enjoinable injury, under bedrock principles of equity jurisdiction.

That courts show an increasing tendency to focus on the overall significance of the relevant threats, rather than solely on the likelihood that the feared consequences will come to pass, is fully consistent with the Restatement (Second) of Torts. It also comports with both modern principles of risk assessment and the analysis that this Court and others have applied in related contexts. And finally, it closely tracks an analogous development in environmental law, the advent of the so-called “imminent hazard” provisions that Congress patterned on public nuisance principles.

In the face of this longstanding history and legal evolution, Monsanto reads this Court’s opinion in Winter as mandating a significant reworking of the basic principles of equitable jurisdiction. Petr.’s Br. 41-47. Winter, however, is far too slender a reed to support such a major change. Indeed, Winter not only fails to signal any such change, it expressly embraces traditional principles. Moreover, it contains no holding at all regarding the irreparable injury requirement.

We of course recognize that judicial enforcement of the statute at issue in this case, the National Environmental Policy Act, 42 U.S.C. § 4321, et seq. (“NEPA”), focuses on the procedures it prescribes. This does not mean, however, that this Court should discount its congressionally-articulated substantive goals when considering the presence of irreparable injury. Congress intended for NEPA to influence governmental decision-making profoundly. To effectuate this goal, Congress required agencies to undertake extensive analysis whenever their actions may “significantly affect” the environment, see 42 U.S.C. § 4332(2)(C) and 40 C.F.R. § 1501.4. That the potential for such effects was intended to trigger action only serves to emphasize why the “likelihood of irreparable injury” requirement should not be deemed to require a more-likely-than-not standard. This Court should honor Congress’s intent that potentially significant environmental risks be examined by ensuring that federal courts have the broad equitable discretion to determine, in appropriate cases, that an agency’s failure to comply with NEPA poses a sufficient threat of harm to constitute a likelihood of irreparable injury, even if that harm is not preponderantly likely to occur.

ARGUMENT

I.                       THE COURTS OF EQUITY LONG HAVE HAD THE AUTHORITY TO ISSUE INJUNCTIONS IN THE FACE OF SIGNIFICANT THREATS.

a.     The history of the common law fully supports the idea that courts may address situations that pose unreasonable harm of injury, and that they may issue injunctions in response to those threats.

Under the common law, courts long have had the power to issue injunctions in the face of significant threats, regardless of whether the threatened harms were at least 51% likely to come to fruition. In these cases, all plaintiffs have been required to show is that the conduct poses a significant threat to the public health, safety, or welfare. They have not been required to show a preponderant likelihood that the threat will result in the feared consequences. The circumstances themselves, if sufficiently threatening, constitute a nuisance and give rise to a claim for injunctive relief.

This power may be most apparent in the realm of public nuisance law. This Court traced the history of the equitable power to address these nuisances in Mugler v. State of Kansas, 123 U.S. 623 (1887):

“In regard to public nuisances,” Mr. Justice Story says, “the jurisdiction of courts of equity seems to be of very ancient date, and has been distinctly traced back to the reign of Queen Elizabeth. The jurisdiction is applicable, not only to public nuisances, strictly so called, but also to purprestures upon public rights and properties. . . . In case of public nuisances, properly so called, an indictment lies to abate them, and to punish the offenders. But an information also lies in equity to redress the grievance by way of injunction.” 2 Story, Eq. Jur. §§ 921, 922. The ground of this jurisdiction in cases on purpresture, as well as of public nuisances, is the ability of courts of equity to give a more speedy, effectual, and permanent remedy than can be had at law. They can not only prevent nuisances that are threatened, and before irreparable mischief ensues, but arrest or abate those in progress, and, by perpetual injunction, protect the public against them in the future; whereas courts of law can only reach existing nuisances, leaving future acts to be the subject of new prosecutions or proceedings. This is salutary jurisdiction, especially where a nuisance affects the health, morals or safety of the community. Though not frequently exercised, the power undoubtedly exists in courts of equity to protect the public against injury. [Citations omitted].

Id. at 672–73 (emphasis added); see also United Steelworkers of Am. v. United States, 361 U.S. 39, 60 (1959) (citing English public nuisance cases involving injunctions as far back as 1587). Additionally, this Court long has recognized that public nuisance doctrine embraces both health and other environmental protection concerns. Georgia v. Tenn. Copper Co., 206 U.S. 230 (1907) (deeming air pollution a public nuisance because of its impacts on both forests and public health in a neighboring state); see also Ariz. Copper Co. v. Gillespie, 230 U.S. 46, 56–57 (1913) (water pollution deemed a public nuisance), and New Jersey v. City of New York, 283 U.S. 473 (1931) (same).

In most nuisance cases, both public and private, the relevant conduct or conditions already have given rise to harm, and thus it is often easy for courts to find a sufficient threat of future harm. That was certainly true in Tennessee Copper, Arizona Copper, and City of New York. In other cases, however, the threat is present but has not yet given rise to harm. Where the courts have deemed such threats sufficiently serious, however, they have not hesitated to find that the conduct or condition constitutes a nuisance, without inquiring into whether the threatened harms were more likely than not to materialize. As early as 1799, for example, upon finding that certain houses in which the defendant was storing sugar were structurally unsound, the chancellor in London v. Bolt, 5 Ves. Jun. 129, 31 Eng. Rep. 507 (Ch. 1799), relied on public nuisance doctrine to issue an injunction preventing the defendant from adding any additional sugar. Similarly, in R. v. Vantandillo, 4 M. & S. 73, 105 Eng. Rep. 762 (K.B. 1815), the court determined that carrying a child with smallpox along a public highway constituted a public nuisance, without any finding regarding the likelihood that this conduct would cause harm to anyone else.[2]

In this country, the earliest cases recognizing that a significant risk could in itself constitute a nuisance arose in the context of private nuisance law. In Tyner v. People’s Gas Co., 132 Ind. 408, 31 N.E. 61 (1892), for example, the Indiana Supreme Court overruled a demurrer where the defendant was intending to use nitroglycerin to “shoot” a well on its property, which the plaintiff alleged would pose a serious, but unquantified, risk of explosion, thus endangering both the plaintiff and his family. The court stated that:

It is settled by our own decisions that the erection or the maintaining of anything that is injurious to health . . . , so as essentially to interfere with the comfortable enjoyment of life or property, constitutes a private nuisance. To live in constant apprehension of death from the explosion of nitroglycerin is certainly an interference with the comfortable enjoyment of life. Injunction is the proper remedy for an injury of this kind.

31 N.E. at 62. Similarly, in Ferry v. City of Seattle, 116 Wash. 648, 303 P. 40 (1922), the Washington Supreme Court affirmed a lower court injunction prohibiting the construction of a dam where it would pose an unacceptable risk to neighboring property owners. Here also, neither the plaintiff nor the court quantified the risk. In its analysis, though, the court explicitly factored in the magnitude of the consequences when discussing their probability:

The test as to whether a structure of the proposed character is to be declared a nuisance turns on whether the complaining property owners are under a reasonable apprehension of danger, and the question of the reasonableness of the apprehension turns again, not only on the probable breaking of the reservoir, but the realization of the extent of the injury which would certainly ensue; that is to say the court will look to consequences in determining whether the fear existing is reasonable. For instance, if the reservoir were being built in some place where, should it break, the resultant damage would be merely to property which could adequately be recompensed, the court would be more apt to hesitate in declaring it a nuisance than where, should a break occur, not only property of immense value would be destroyed, but many lives would be lost
as well.

Id. at 662.

Early treatises also recognized the need to apply a sliding scale regarding the likelihood of the harm in situations in which the consequences may be severe. As early as in 1919, Pomeroy’s Treatise on Equitable Remedies provided that:

. . . On the one hand, a mere possibility of a future nuisance will not support an injunction; it must be probable. On the other hand, the plaintiff . . . does not need to establish this probability by proof amounting to a virtual certainty that the nuisance will occur, nor even proof which establishes it beyond a reasonable doubt; it is sufficient if he show that the risk of its happening is greater than a reasonable man would incur. And the balance between these two rules will be affected by the seriousness of the nuisance feared, the strength required for the plaintiff’s proof diminishing somewhat as the greatness of the apprehended damage increases.

Pomeroy, A Treatise on Equity Jurisprudence and Equitable Remedies, Vol. 5, § 523, p. 4398 (1919) (emphasis added).

By the middle of the 20th century, courts were applying this logic in the public nuisance context. In Harris Stanley Coal & Land Co. v. Chesapeake & Ohio Railway Co., 154 F.2d 450 (6th Cir. 1946), cert. denied, 329 U.S. 761 (1946), a railroad appealed the district court’s denial of an injunction through which the railroad sought to preclude a mining company from removing pillars of coal that were designed to support the surface of the land. Id. at 452. The lower court had found that there was a “possibility or even probability that the mountain side would slip or subside,” but nonetheless denied the injunction. Id. The Sixth Circuit reversed, emphasizing the seriousness of the potential consequences:

If the threatened injury to the railroad right-of-way be envisioned merely as the sliding of some of the surface material of the mountain upon the railroad right-of-way necessitating some expense in its removal and in the repair of the roadbed, we might well say that recovery of damages in a suit at law provides adequate remedy. We have here, however, a railroad over which pass trains bearing passengers and freight. Their daily number is not disclosed by the record, and being but a branch line it may be assumed that the traffic is not heavy. Nevertheless, traffic there is, and the effect of a substantial mountain slide upon a passing train might well be catastrophic. It may be that such disaster could occur only upon a concatenation of circumstances of not too great probability, and that the odds are against it. It is common experience, however, that catastrophies occur at unexpected times and in unforeseen places.. . . A court of equity will not gamble with human life, at whatever odds, and for loss of life there is no remedy at law.

Id. at 453; see also County of San Diego v. C.W. Carlstrom, 196 Cal. App. 2d 485, 16 Cal. Rptr. 667 (1961) (finding a fire hazard to be a public nuisance without any quantification regarding the likelihood of a fire).

More recently, the courts have applied this kind of risk-based logic in a broader array of equitable contexts, finding nuisances and authorizing injunctive relief in situations where it has been far from certain that the relevant threat, while significant, was likely to give rise to the feared consequences. Perhaps most tellingly, this Court in Lucas v. South Carolina Coastal Council, 505 U.S. 1003 (1992), implicitly assumed that risk analysis can play a role in determining what constitutes a nuisance. There, in exploring the relationship between takings law and nuisance principles, the Court insisted that “the corporate owner of a nuclear generating plant” could not successfully raise a takings claim “when it is directed to remove all improvements from its land upon discovery that the plant sits astride an earthquake fault.” Id. at 1029. The mere existence of a fault in such a situation would not, of course, make an earthquake more likely than not, let alone create a likelihood of radioactive release. As the Court appeared to recognize, it is the severity of the potential consequences that would make the threat abatable as a public or private nuisance, and hence undermine a takings claim.

Other courts have applied a similar calculus to nuisance cases involving hazardous waste contamination[3] and threats to the public safety from the possibility of gang violence,[4] over-aggressive protesters,[5] and potentially violent demonstrations.[6] In none of these cases did the courts feel the need to quantify the likelihood that the threatened harms would come to pass. After identifying a significant threat to the public weal, they simply found nuisances to exist and issued injunctions designed to abate them.

b. The Restatement (Second) of Torts is fully in accord with
these cases.

The Restatement (Second) of Torts (“Restatement”) expressly contemplates that conduct and conditions giving rise to unreasonable risks of harm are actionable under principles of both public and private nuisance. It further contemplates that courts may enjoin these injuries without first finding a preponderant likelihood that the relevant harm will materialize.

Turning first to public nuisances, the Restatement defines such a nuisance as “an unreasonable interference with a right common to the general public.” Restatement (Second) of Torts § 821B (1977). It further provides that “[c]ircumstances that may sustain a holding that an interference with a public right is unreasonable include [situations in which] the conduct involves a significant interference with the public health, the public safety, the public peace, the public comfort or the public convenience.” Id. Comment b to that section lists “the maintenance of a pond breeding malarial mosquitoes” as an example of an interference with the public health, and “bad odors, dust and smoke” as examples of interferences with the public comfort. Id. § 821B, cmt. b, p. 88. Elsewhere, the Restatement cites pollution leading to a beach closure as yet another example of a public nuisance. Id. § 832, cmt. b, p. 143.

Under the Restatement, an “unreasonable” or “significant” interference with the public health, safety, peace, comfort, or convenience is all that is required. Nothing in the Restatement suggests that public-nuisance plaintiffs must show a preponderant likelihood that someone will actually get sick or suffer a physical injury or some other clear manifestation of harm, either as part of their prima facie case or to establish an entitlement to equitable relief. In the beach closure context, for example, it is presumed that a health threat warranting beach closure is actionable, without any required showing that would-be swimmers face at least a 51% likelihood of becoming ill.

The provisions of the Restatement pertaining to private nuisances apply similar logic. Section 821D defines a private nuisance as a “nontrespassory invasion of another’s interest in the private use or enjoyment of land.” Id. § 821D. Sections 821F and 822 note that the harm must be both “significant” and either “intentional and unreasonable” or “unintentional and otherwise actionable” under either negligence standards or principles of strict liability. Id. §§ 821F and 822, respectively.[7]

It is in the Comments to § 822 that the Restatement makes clear that a significant risk of harm constitutes a cognizable injury under this formulation. Comment g, addressing the unreasonableness requirement in the context of intentional invasions, provides that:

. . . The very existence of organized society depends upon the principle of “give and take, live and let live,” and therefore the law of torts does not attempt to impose liability or shift the loss in every case in which one person’s conduct has some detrimental effect on another. Liability for damages[8] is imposed in those cases in which the harm or risk to one is greater than he ought to be required to bear under the circumstances, at least without compensation.[9]

Id. § 822, cmt. g, p. 112 (emphasis added).

Chapter 48 of the Restatement, which deals specifically with the appropriateness of tort-related injunctions, further illuminates the role that risk plays in both public and private nuisance doctrine. First, § 933(1) indicates that injunctions are available for both committed and threatened torts, depending upon the appropriateness of such issuance as determined by the factors listed in § 936. Id. § 933(1). In turn, § 936(1) contemplates a “comparative appraisal of all of the factors in the case,” including:

(a) the nature of the interest to be protected,

(b) the relative adequacy to the plaintiff of injunction and other remedies,

(c) any unreasonable delay by the plaintiff in bringing suit,

(d) any related misconduct on the part of the plaintiff,

(e) the relative hardship likely to result to defendant if an injunction is granted and to plaintiff if it is denied,

(f) the interests of third persons and of the public, and

(g) the practicability of framing or enforcing the order or judgment.

Id. § 936(1).

In Comment b to Section 933, the Restatement more thoroughly addresses the need to enjoin improbable but serious harms, when it discusses “threatened torts.” There, it speaks in the following terms:

The expression “threatened tort,” as used in Subsection (1) of this Section, contemplates, as a condition for the grant of an injunction, a threat of sufficient seriousness and imminence to justify coercive relief. The seriousness and imminence of the threat are in a sense independent of each other, since a serious harm may be only remotely likely to materialize and a trivial harm may be quite imminent. Yet the two elements must be considered together in the decision of any given case. The more serious the impending harm, the less justification there is for taking the chances that are involved in pronouncing the harm too remote.

Id. § 933, cmt. b, p. 561 (emphasis added). A comment to § 821F both emphasizes this point and makes it specifically applicable to both public and private nuisances:

. . . [E]ither a public or private nuisance may be enjoined because harm is threatened that would be significant if it occurred, and that would make the nuisance actionable under the rule here stated, although no harm has
yet resulted.

Id. § 821F, cmt. b, p. 105.

In short, the Restatement contemplates that the significance of the risk can be considered in determining both whether a nuisance exists and whether injunctive relief is an appropriate remedy. In neither context is it necessary that there be a preponderant likelihood that the threatened harm will come to pass; if the potential harm is particularly serious, the Restatement contemplates that courts will be prepared to guard against even a low likelihood of its occurring.

Finally, once a nuisance has been established, the Restatement does not require a separate showing regarding the likelihood of irreparable injury. Section 936(1) includes the other traditional equitable factors, but not that one. Although this goes unexplained in the Restatement, the only logical conclusion is that the nuisance finding equates to a finding that there is a sufficient likelihood of irreparable injury.[10] This interpretation draws support from § 7 of the Restatement, which distinguishes the concept of “injury” from that of “harm.” The word “injury,” it makes clear, denotes “the invasion of any legally protected interest of another,” as distinct from “harm,” which is used to mean an actual loss or detriment. Id. § 7 (1965). Thus, under the Restatement one can be irreparably injured without having actually been harmed.

c. The tendency of courts to issue injunctions in the face of significant threats comports with sound risk analysis and the approaches that this Court and others have taken in analogous contexts.

If there is one unifying principle in the modern regulatory world, it is that analyzing risk requires an understanding not only of the likelihood of a particular outcome, but also of the severity of its potential effects.
Nat’l Research Council, Science and Judgment in Risk Assessment 4
(1994); School Bd. of Nassau County, Fla. v. Arline, 480 U.S. 273, 287–88 (1987) ( “Arline”).

Ever since Judge Hand first analyzed negligence issues in terms of whether the burden of the relevant precautions was less than the probability of an accident, multiplied by the gravity of the resulting injury, United States v. Carroll Towing Co., 159 F.2d 169 (2d Cir. 1947), courts have increasingly embraced modern risk analysis. This Court expressly embraced the fundamental principles of risk assessment in Arline. As the Court later summarized in Bragdon v. Abbott, 524 U.S. 624 (1998), Arline dealt with the

. . . importance of prohibiting discrimination against individuals with disabilities while protecting others from significant health and safety risks, resulting, for instance, from a contagious disease. In Arline, the Court reconciled these objectives by construing the [relevant statute] not to require the hiring of a person who posed a significant risk of communicating an infectious disease to others.

Id. at 649 (quotation omitted). In Arline, the Court determined that the “significance” inquiry should include:

“[findings of] facts, based on reasonable medical judgments given the state of medical knowledge, about (a) the nature of the risk (how the disease is transmitted), (b) the duration of the risk (how long is the carrier infectious), (c) the severity of the risk (what is the potential harm to third parties) and (d) the probabilities the disease will be transmitted and will cause varying degrees of harm.”

Arline, 480 U.S. at 288 (quoting from a brief filed by the American Medical Association).

This Court also squarely embraced a “significant threats” approach in Helling v. McKinney, 509 U.S. 25 (1993). There, the Court determined that the Eighth Amendment’s “cruel and unusual punishment” standard forbids not only prison conditions that are likely to make a particular inmate ill, but  also those that pose “an unreasonable risk of serious damage to [a prisoner’s] future health.” Id. at 35.

The lower courts have applied similar logic in related contexts. Most significantly, they have adopted risk-based ideas in applying the “likelihood of prevailing on the merits” standard that governs the issuance of preliminary injunctions. In American Hospital Supply Corp. v. Hospital Products Ltd., 780 F.2d 589 (7th Cir. 1986), for example, Judge Posner wrote that:

A district judge asked to decide whether to grant or deny a preliminary injunction must choose the course of action that will minimize the costs of being mistaken. Because he is forced to act on an incomplete record, the danger of a mistake is substantial. And a mistake can be costly. If the judge grants the preliminary injunction to a plaintiff who it later turns out is not entitled to any judicial relief – whose legal rights have not been violated – the judge commits a mistake whose gravity is measured by the irreparable harm, if any, that the injunction causes to the defendant while it is in effect. If the judge denies the preliminary injunction to a plaintiff who it later turns out is entitled to judicial relief, the judge commits a mistake whose gravity is measured by the irreparable harm, if any, that the denial of the preliminary injunction does to the plaintiff.

These mistakes can be compared, and the one likely to be less costly can be selected, with the help of a simple formula: grant the preliminary injunction if but only if P x Hp > (1 – P) x Hd, or, in words, only if the harm to the plaintiff if the injunction is denied, multiplied by the probability that the denial would be an error (that the plaintiff, in other words, will win at trial), exceeds the harm to the defendant if the injunction is granted, multiplied by the probability that granting the injunction would be an error. That probability is simply one minus the probability that the plaintiff will win at trial; for if the plaintiff has, say, a 40 percent chance of winning, the defendant must have a 60 percent chance of winning (1.00 – .40 = .60). The left-hand side of the formula is simply the probability of an erroneous denial weighted by the cost of denial to the plaintiff, and the right-hand side simply the probability of an erroneous grant weighted by the cost of grant to the defendant.

Id. at 593; see also FoodCom Int’l v. Barry, 328 F.3d 300, 303 (7th Cir. 2003). Similarly, the Second Circuit has applied a sliding-scale approach in the same context, requiring “either (1) likelihood of success on the merits or (2) sufficiently serious questions going to the merits to make them a fair ground for litigation and a balance of hardships tipping decidedly toward the party requesting the preliminary relief.” Jackson Dairy, Inc. v. H.P. Hood & Sons, Inc., 596 F.2d 70, 72 (2d Cir. 1979).[11]

d. Congress has recognized the importance of risk analysis in injunctive settings when it codified public nuisance principles
in various environmental laws. Courts have done the same in applying those provisions.

In the environmental realm, risk assessment principles manifest themselves in various ways.[12] The place where Congress has made most apparent its embrace of risk assessment principles specifically in the injunctive relief context is in the so-called “imminent hazard” provisions in several pollution control statutes. See, e.g., 42 U.S.C. §§ 6973, 9606. Congress expressly patterned these provisions on public nuisance principles. See, e.g., S. Rep. No. 96-172., 1st Sess., at 5, as reprinted in (1980) U.S.C.C.A.N. 5019, 5023; see also United States v. Waste Indus., Inc., 734 F.2d 159 (4th Cir. 1984).

Sections 7002(a)(1)(B) and 7003 of the Resource Conservation and Recovery Act, 42 U.S.C. § 6972(a)(1)(B) and 6973, are typical of these provisions. Under these provisions, Congress empowered the courts to issue injunctions, at either citizens’ or the Government’s behest (respectively), whenever the handling or disposal of any solid or hazardous waste “may present an imminent and substantial endangerment to health or the environment.” In keeping with this language, courts have found that Congress authorized relief whenever there is a “reasonable cause for concern that someone or something may be exposed to a risk of harm by a release or a threatened release of a hazardous substance if remedial action is not taken.” Interfaith Comty. Org. v. Honeywell Int’l., Inc., 399 F.3d 248, 259 (3d Cir. 2005) (upholding injunction in a citizen suit).[13] In Reserve Mining Co. v. Environmental Protection Agency, 514 F.2d 492 (8th Cir. 1975), the Eighth Circuit elaborated on this idea in a case involving a predecessor to the Clean Water Act’s current “imminent hazard” provision:

These concepts of potential harm, whether they be assessed as “probabilities and consequences” or “risk and harm,” necessarily must apply in a determination of whether any relief should be given in cases of this kind in which proof with certainty is impossible. The district court, although not following a precise probabilities-consequences analysis, did consider the medical and scientific evidence bearing on both the probability of harm and the consequences should the hypothesis advanced by the plaintiffs prove to be valid.

In assessing probabilities in this case, it cannot be said that the probability of harm is more likely than not. Moreover, the level of probability does not readily convert into a prediction of consequences. On this record it cannot be forecast that the rates of cancer will increase from drinking Lake Superior water or breathing Silver Bay air. The best that can be said is that the existence of this asbestos contaminant in air and water gives rise to a reasonable medical concern for the public health. The public’s exposure to asbestos fibers in air and water creates some health risk. Such a contaminant should be removed.

Id. at 520.

II. WINTER DID NOT ALTER THE TRADITIONAL EQUITABLE REQUIREMENTS FOR AN INJUNCTION.

In Winter, this Court indicated that the Ninth Circuit had erred in determining that any “possibility” of irreparable injury was sufficient to satisfy the irreparable injury threshold in NEPA cases. 129 S. Ct. at 375 (citing, inter alia, Faith Center Church Evangelistic Ministries v. Glover,
480 F.3d 891, 906 (9th Cir. 2007)
). Significantly, however, the Court did not articulate the circumstances in which an actual threat of significant harm can constitute a sufficient likelihood of irreparable injury. Nor did it indicate that it was altering the traditional principles of equitable relief in any way;
to the contrary, the Court’s entire discussion is framed as an application of those basic principles. Id. at 374–82.

Moreover, specifically with regard to the “likelihood of irreparable injury” standard, the Winter Court declined to make any finding regarding whether the plaintiff had met the equitable test. Instead, despite the Navy’s contention that there had been no documented harm to marine mammals during 40 years of similar training in the relevant area, the Court specifically rested its holding on other grounds, concluding that “even if plaintiffs have shown irreparable injury from the Navy’s training exercises, any such injury is outweighed by the public interest and the Navy’s interest in effective, realistic training of its sailors.” Id. at 376.

Monsanto’s argument in this case is wholly premised on the idea that Winter altered the traditional equitable test regarding the likelihood of irreparable injury. See Petr.’s Br. 41–47. Winter, however, did no such thing. The Court’s “irreparable injury” discussion in Winter simply cannot bear the weight Monsanto puts on it.

III. THAT NEPA IMPOSES ONLY PROCEDURAL MANDATES SHOULD NOT UNDERMINE THE ABILITY OF THE COURTS TO ENJOIN ACTIONS THAT WILL LIKELY LEAD TO IRREPARABLE INJURY.

Most environmental statutes contain enforceable substantive mandates. See, e.g., 33 U.S.C. § 1311(b) (Clean Water Act). In that context, it may be that violations of those standards should constitute irreparable harm as a matter of law. This conclusion would seem consistent with United States v. Oakland Cannabis Buyers’ Cooperative, 532 U.S. 483 (2001) (“Oakland Cannabis”). In that case, this Court held that:

. . . [A] court sitting in equity cannot ignore the judgment of Congress, deliberately expressed in legislation. A district court cannot, for example, override Congress’ policy choice, articulated in a statute, as to what behavior should be prohibited. Once Congress, exercising its delegated powers, has decided the order of priorities in a given area, it is . . . for the courts to enforce them when enforcement is sought. Courts of equity cannot, in their discretion, reject the balance that Congress has struck in a statute. Their choice (unless there is statutory language to the contrary) is simply whether a particular means of enforcing the statute should be chosen over another permissible means; their choice is not whether enforcement is preferable to no enforcement at all. Consequently, when a court of equity exercises its discretion, it may not consider the advantages and disadvantages of nonenforcement of the statute, but only the advantages and disadvantages of employing the extraordinary remedy of injunction over other available methods of enforcement. To the extent the district court considers the public interest and the conveniences of the parties, the court is limited to evaluating how such interest and conveniences are affected by the selection of an injunction over other enforcement mechanisms.

Oakland Cannabis, 532 U.S. at 497–498 (internal quotations and footnotes  omitted).[14]

While this Court has determined that NEPA “imposes on agencies duties that are essentially procedural,” Strycker’s Bay Neighborhood Council, Inc. v. Karlen, 444 U.S. 223, 227 (1980), it also has recognized that the statute has broad substantive goals. Id.; see also Robertson v. Methow Valley Citizens Council, 490 U.S. 332, 350–51 (1989). Among its other objectives, Congress sought through NEPA to “assure for all Americans safe, healthful, productive, and esthetically pleasing surroundings.” 42 U.S.C. § 4331(b)(2). That Congress sought to achieve these goals through procedural means does not undermine the seriousness of the goals themselves. As this Court noted:

The sweeping policy goals announced in § 101 of NEPA are [to be] realized through a set of action-forcing procedures that require that agencies take a hard look at environmental consequences, and that provide for broad dissemination of relevant environmental information. . . .

Methow Valley, 490 U.S. at 350 (internal quotations omitted). The Methow Valley Court also noted that “these procedures are almost certain to affect the agency’s substantive decision.” Id.

The plaintiffs in this case have a legal injury and cannot be adequately compensated by monetary damages.[15] Additionally, the real-world threats here at issue are serious and have not been adequately studied, as required by Congress. In situations where, as here, there is a reasonable prospect of significant harm, lower courts should have the discretion to determine whether an agency’s failure to comply with the law entails a sufficient likelihood of irreparable injury to support equitable relief. This is particularly true in the context of a statute such as NEPA, where Congress has expressly recognized “the critical importance of  . . . maintaining environmental quality,” 42 U.S.C. § 4331(a), and “direct[ed] that, to the fullest extent possible: (1) the policies, regulations, and public laws of the United States shall be interpreted and administered in accordance with [NEPA’s] policies. . . .” 42 U.S.C. § 4332.

In other contexts this Court has not hesitated to invoke its equitable powers to address procedural violations in the absence of any affirmative demonstration of a preponderant likelihood of substantive irreparable harm. In Clark v. Roemer, 500 U.S. 646 (1991), for example, the Court dealt with a violation of the “preclearance” provisions in § 5 of the Voting Rights Act of 1965, 42 U.S.C. § 1973c. In that case, the district court had allowed both an election to go forward and the winners to assume their offices (at least provisionally), despite violations of § 5. A unanimous Court reversed, holding that the district court was required to enjoin the illegal election. Id. at 654. The Court did this without any inquiry into whether the plaintiffs had shown that the procedural violation—the State’s failure to obtain preclearance—had led or was likely to lead to any irreparable harm.[16] Instead, the Court announced a nearly automatic rule that injunctions should issue in these contexts:

We need not decide today whether there are cases in which a district court may deny a § 5 plaintiff’s motion for injunction and allow an election for an unprecleared seat to go forward. An extreme circumstance might be present if a seat’s unprecleared status is not drawn to the attention of the State until the eve of the election and there are equitable principles that justify allowing the election to proceed. No such exigency exists here.

Id. at 654–655; see also Branch v. Smith, 538 U.S. 254 (2003).

Of course, NEPA is not the Voting Rights Act. However, NEPA plaintiffs such as Geertson Seed Farms stand to suffer substantive and legally cognizable injuries, which may be avoided if the required procedures are followed. And, as in this case, the real world harms at stake in NEPA cases can be quite significant.[17] Moreover, the NEPA process can and often does make a substantive difference. Again, in Methow Valley this Court deemed that prospect “almost certain.” 490 U.S. at 350. Indeed, as this Court noted in Lujan v. Defenders of Wildlife, 504 U.S. 555, 573 n.7 (1992), it is that very possibility that gives those who live near proposed federal projects redressability for Article III purposes.

Courts have always construed the elements required for equitable relief in a flexible fashion, with due deference to trial court judges. As seen above, the “likelihood of irreparable injury” standard is perfectly well suited to averting substantial risks of significant harm, even absent a preponderant likelihood that the harm will come to pass. In the NEPA context, there may certainly be some cases where the threat of significant harm is so minor that the legal injury any potential plaintiffs could suffer should not, by itself, be deemed to meet the irreparable injury requirement. This case, however, is not one of them.

 

Respectfully submitted,

Allison M. LaPlante

 

APPENDIX

Description of Amici Curiae

The Natural Resources Defense Council is one of the nation’s leading environmental organizations, with 1.2 million members and supporters. Its mission is to safeguard the Earth: its people, its plants and animals and the natural systems on which all life depends.

 

Craig N. Johnston is a professor of law at Lewis & Clark Law School, where he teaches courses in environmental law and environmental enforcement, among other courses. Prof. Johnston also has coauthored casebooks in both environmental law and hazardous waste law.

 

Michael C. Blumm is a professor of law at Lewis & Clark Law School, where he teaches property, legal history and other courses. Professor Blumm has written widely on environmental issues.

 

David W. Case is an associate professor of law at the University of Mississippi, where he teaches civil procedure, contracts, and environmental law. He has also written extensively in the field of environmental law.

 

Jamison E. Colburn is a professor of law at Pennsylvania State University, where he teaches constitutional law, administrative law, and environmental law. He has written widely on administrative and environmental issues.

 

William F. Funk is a professor of law at Lewis & Clark Law School, where he teaches environmental law and other courses. Prof. Funk has coauthored casebooks in constitutional law, environmental law and administrative law.

 

David K. Mears is an associate professor of law at Vermont Law School, where he teaches property and environmental law. Professor Mears also directs the law school’s Environmental and Natural Resources Law Clinic.

 

Patrick A. Parenteau is a professor of law at Vermont Law School, where he is senior counsel to the school’s Environment and Natural Resources Law Clinic. Prof. Parenteau also teaches many courses, including one on environmental litigation.

 

John T. Parry is a professor of law at Lewis & Clark Law School, where he teaches criminal law, civil procedure, and other courses. Professor Parry has also written several books on the law of torture.

 

Melissa A. Powers is an assistant professor of law at Lewis & Clark Law School. Professor Powers teaches torts and energy law, among other courses. She has coauthored a casebook on climate change and the law.

 

Mary C. Wood is the Phillip H. Knight Professor at the University of Oregon School of law. Prof. Wood teaches and publishes in the fields of property, environmental, and Indian law.

 

 


* Professor of Law, Lewis & Clark Law School; B.A., 1978 University of Rochester; J.D., magna cum laude, 1985 Lewis & Clark Law School. Because Professor Johnston is not currently an active member of the Oregon bar, he could not be the counsel of record on this brief. While Ms. LaPlante reviewed the brief before it was filed, Professor Johnston was its author. The author would like to thank Brett Hartl, Ben Luckett, Amy van Saun, Nate Hausman, and Elizabeth Zultoski for their terrific research assistance. Additionally, he would like to thank Niel Lawrence, Nancy Marks, and Professors Allison LaPlante, Tomás Gómez-Arostegui, and Bill Funk for their outstanding comments on prior drafts.

[1] The Government’s written consent to the filing of this brief is on file with the Clerk of this Court. The other parties’ written consents are being submitted with this brief. Pursuant to S. Ct. R. 37.6, amici affirm that this brief was not authored in whole or in part by counsel for a party, and that no monetary contribution to the preparation or submission of this brief was made by any person other than amici or their counsel.

[2] This was a criminal case brought in the King’s Bench, a court which in 1815 could not grant injunctions. We cite it here as an example of another early decision deeming conduct threatening to the public weal to constitute a public nuisance, without either quantifying the risk or concluding that the threatened harm was likely to materialize.

[3] See, e.g., Village of Wilsonville v. SCA Servs., Inc., 77 Ill. App. 3d 618, 635–636, 396 N.E.2d 552, 564 (4th Dist. 1979), aff’d, 86 Ill. 2d 1, 426 N.E.2d 824 (1981) (“The trial court could have determined from the evidence that the harm that would impend because of the danger that hazardous substances might escape was so serious that no justification existed to deny the injunction even though the feared harm was uncertain as to occurrence and, in any event, unlikely to occur until the distant future.”); Wood v. Picillo, 443 A.2d 1244, 1247 (1982) (“According to experts, the chemicals present on defendant’s property and in the marsh, left unchecked, would eventually threaten wildlife and humans well downstream from the dump site.”).

[4] People ex rel. Gallo v. Acuna, 14 Cal. 4th 1090, 929 P.2d 596, 60 Cal. Rptr. 2d 277 (1997).

[5]    See N.Y. State Nat’l Org. for Women v. Terry, 886 F.2d 1339, 1362 (2d Cir.), cert. denied, 495 U.S. 1339 (1989) (“We have no doubt that-absent the requested relief-the health and security of a considerable number of persons was and would be endangered by the demonstrations. Accordingly, the district court correctly found that defendants’ activities constituted a public nuisance, and properly granted the City summary judgment on this claim.”); Hirsh v. City of Atlanta, 261 Ga. 22, 401 S.E.2d 530 (1991).

[6] Wilkinson v. Forst, 832 F.2d 1330 (2d Cir. 1987), cert. denied sub nom. Kelly v. Wilkinson, 485 U.S. 1034 (1988) (authorizing magnetometer searches); but see Christian Knights of the Ku Klux Klan Invisible Empire, Inc. v. Dist. of Columbia, 972 F.2d 365 (D.C. Cir. 1992) (identifying First Amendment constraints that might limit injunctions such as those allowed to stand in Wilkinson).

[7] A comment to the former provision indicates that “significant” means “harm of importance, involving more than slight inconvenience or petty annoyance.” Restatement, supra, § 821F, cmt. c, p. 105.

[8] Although this provision speaks explicitly only to liability for damages, the Restatement makes clear that injunctive relief is available in appropriate cases for private nuisances. See, infra, pp. 18–19. It is perhaps for this reason that the authors of Prosser and Keaton on Torts edited out the words “for damages” when they quoted this passage in their treatise. Prosser and Keaton on Torts, 5th Ed., p. 629 (1984).

[9] Comment k, dealing with unintentional invasions, also focuses on risk. Because that note addresses liability based on negligence theories, however, it emphasizes that “it is the risk of harm that makes the conduct unreasonable.” Restatement, supra, § 822, cmt. k, p. 114.

[10] The only reference to anything like an irreparable harm requirement is in Comment b, which includes a statement that:

. . . Other factors, not here listed, may be considered, as for example, that of the sufficiency of the seriousness and imminence of the threat of tort, discussed in § 933(1), Comment b.

Restatement, supra, § 936(1), cmt. b, p.567. This of course, though, merely replicates the analysis necessary in the first place to determine whether there is a qualifying tort.

[11] Black’s Law Dictionary has gone even further in relaxing the likelihood standard, defining the likelihood-of-success-on-the-merits test as requiring only “a reasonable probability of success in the litigation or appeal.” Black’s Law Dictionary 947 (8th ed. 2004); see also AlliedSignal, Inc. v. B.F. Goodrich Co., 183 F.3d 568, 576 (7th Cir. 1999) (applying an unquantified “substantial likelihood of irreparable harm” test in an antitrust case).

[12] Under some environmental statutes, certain harms are seen as being so serious that our laws speak in absolute terms. The most famous example of this is the Endangered Species Act, under which, as this Court has recognized, in barring harm to endangered species or their critical habitat, “Congress has spoken in the plainest of terms, making it abundantly clear that the balance has been struck in favor of affording endangered species the highest of priorities.” Tenn. Valley Auth. v. Hill, 437 U.S. 153, 194 (1978) (applying 16 U.S.C. § 1536(a)). In other contexts, Congress and/or the agencies that implement the relevant statutes have set substantive standards according to what they deem to be acceptable risk ranges given the perceived severity of the potential adverse effects. Under the Comprehensive Environmental Response, Compensation and Liability Act, 42 U.S.C. § 9601, et seq., for example, the Environmental Protection Agency must clean up sites to a degree that reduces the cancer threat to those living nearby to a risk range of between one-in-ten-thousand (1xl0-4) and one-in-a-million (1×10-6), with the latter standard serving as the “point of departure.” 40 C.F.R. § 300.430(e)(2)(i)(A)(2); see also 42 U.S.C. § 9621(b)(1). In the nuclear context, the Nuclear Regulatory Commission’s design requirements for nuclear power plants contemplate that siting decisions control for “design basis events.” These requirements generally ensure that these facilities will not release significant radiation levels during events (such as aircraft accidents) that are found to have more than a one-in-ten-million chance of occurring. See, e.g., 10 C.F.R. §§ 52.17, 52.79, 100.10, 100.20, 100.21; NUREG-0800, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants (SRP), Section 3.5.1.6, “Aircraft Hazards” (Rev. 4, Mar. 2010) (ML070510639), at 3.5.1.6-4 (providing that Part 52 and Part 100 regulations are satisfied “if the probability of aircraft accidents resulting in radiological consequences greater than the 10 [C.F.R.] Part 100 exposure guidelines is less than order of magnitude of 10-7 [one in ten million] per year”).

[13] See also United States v. Conservation Chem. Co., 619 F. Supp. 162, 194 (W.D. Mo. 1985) (applying the same standard under § 106 of the Comprehensive Environmental Response, Compensation, and Liability Act, 42 U.S.C. § 9606).

[14] See also Tenn. Valley Auth. v. Hill, 437 U.S. 153 (1978), and United States v. Mass. Water Res. Auth., 256 F.3d 36, 51 n.15 (1st Cir. 2001). Weinberger v. Romero-Barcelo, 456 U.S. 305 (1982), is not to the contrary. Indeed, a careful reading of it supports this position.
In Romero-Barcelo, this Court upheld the district court’s decision not to enjoin the relevant discharges under § 309(b) of the Clean Water Act, 33 U.S.C. § 1319(b). It did so under the equitable-balancing prong of the injunctive-relief calculus, and in a context in which the relevant violation was procedural—the failure to obtain a permit—not substantive. Id. at
312–19. The Court concluded that “the integrity of the Nation’s waters, . . . not the permit process, is the purpose of the [Clean Water Act].” Id. at 314. The Court did not, however, find an absence of irreparable harm, even though it emphasized the lower court’s finding that that the relevant discharges were not causing any measureable harm to the waters. Id. at 310. The Court underscored the limited nature of its pronouncement in its penultimate paragraph:

. . . The District Court did not face a situation in which a permit would very likely not issue, and the requirements and objective of the statute could therefore not be vindicated if discharges were permitted to continue. Should it become clear that no permit will be issued and that compliance with [the Act] will not be forthcoming, the statutory scheme and purpose would require the court to reconsider the balance it has struck.

Id. at 320 (emphasis added).

[15] See Amoco Production Co. v. Village of Gambell, 480 U.S. 531, 545 (1987) (“[E]nvironmental injury, by its nature, can seldom be adequately remedied by money damages and is often permanent or at least of long duration, i.e., irreparable.”).

[16] In a later case, the Court made clear that the presence or absence of harm is not an issue in preclearance cases:

Nor does it matter for the preclearance requirement whether the change works in favor of, works against, or is neutral in its impact upon the ability of minorities to vote. . . . [P]reclearance is a process aimed at preserving the status quo until the Attorney General or the courts have an opportunity to evaluate a proposed change.

Young v. Fordice, 520 U.S. 273, 285 (1993) (internal citations omitted).

[17] See also Sierra Club v. U.S. Army Corps of Eng’rs., 701 F.2d 1011 (2d Cir. 1983) (Corps was poised to fill in a “highly significant and productive habitat” for striped bass in the Hudson River, which was the second most important contributor of those fish in the Atlantic Coast fishery), Found. on Econ. Trends v. Weinberger, 610 F. Supp. 829 (D.D.C. 1985) (finding that the Army had failed to consider “serious and farreaching” risks relating to the use of pathogenic agents and toxins at a test laboratory), and Sierra Club v. Coleman, 405 F. Supp. 53, 55
(D.D.C. 1975)
 (finding that the Federal Highway Administration failed to adequately address the risks of aftosa, which the record revealed could have resulted in the destruction of 25% of North American livestock if not adequately contained).

BLM’s Retained Rights: How Requiring Environmental Protection Fulfills Oil and Gas Lease Obligations

By Bruce M. Pendery *

There are approximately 39,000,000 acres of federal mineral estate in the eleven western states subject to onshore oil and gas leases issued by the Bureau of Land Management (BLM). The leases grant the lessee the right to extract any oil or natural gas that may be found on the lease. However, the leases make the grant of rights “subject to” a number of reservations of authority to the federal government. The BLM lease provides that these retained rights stem from applicable laws; the terms, conditions, and stipulations in the lease; the Secretary of Interior’s regulations and formal orders in effect when the lease is issued; and regulations and formal orders issued afterward if not inconsistent with the lease rights granted. A BLM regulation makes the lease subject to three further reservations of authority: stipulations; restrictions deriving from specific, nondiscretionary statutes; and reasonable measures the BLM authorized officer might require.
A review of these authorities shows BLM retains substantial rights allowing it to regulate the time, place, and manner of oil and gas development. Development can be conditioned by regulating the timing of operations and the siting and design of facilities, as well as specification of the rates of oil and gas development and production. BLM can suspend operation of leases and can even prohibit development if impacts are substantially different or greater than normal. BLM retains the right to prevent “adverse impacts” by requiring “reasonable measures” to prevent environmental harms. These rights stem from provisions in the Mineral Leasing Act, Federal Land Policy and Management Act, National Environmental Policy Act, Endangered Species Act, Clean Air Act, Clean Water Act, National Historic Preservation Act, other statutes, BLM’s leasing and operations regulations, the terms in the lease itself, and formal orders such as BLM Resource Management Plans, Onshore Oil and Gas Order Number 1, Executive Orders, and Secretarial and Department of Interior Solicitor Orders and Opinions, all of which the lease is made “subject to.” If BLM fully exercises these retained rights it can considerably reduce environmental disturbance due to oil and gas development on the public lands. Means available for exercising these retained rights include requiring phased or paced development, directional drilling, suspension of operations on leases in the interest of conservation of resources, unitization of leases, and a number of best management practices, including placing netting over waste pits to reduce wildlife mortality, requiring “closed-loop” drilling fluid systems to reduce pollution, and requiring mats to be placed on the ground during drilling to reduce drilling impacts, to name a few. This Article argues that given the mandatory, nondiscretionary nature of many of the authorities a federal onshore oil and gas lease has been made subject to, not only does BLM have numerous retained rights, it in fact has an obligation to fully assert them, and several policy changes that could accomplish this are suggested.

 

I. Introduction

There are large areas of the public lands in the western United States that are encumbered by federal oil and natural gas leases. In the eleven western states of New Mexico, Colorado, Wyoming, Montana, Idaho, Utah, Arizona, Nevada, California, Oregon, and Washington—where public lands are an important aspect of land use, economic development, and social structure and culture—there were 404,500,000 acres of federal mineral estate, and over 39,000,000 acres of that estate were subject to federal oil and gas leases in fiscal year 2008.[1]

Given the large areas of public land encumbered by federal onshore oil and natural gas leases, a significant question relates to the “retained rights” enjoyed by the federal government in areas it has leased. This Article posits that the federal government has substantial retained rights allowing it to regulate oil and gas development in order to ensure protection of other resources on the lands it has leased. I define the term “retained rights” to mean powers the federal government maintains and has not ceded regarding public lands management when it issues an onshore oil and gas lease to a private party. As will be explained, the government has retained significant rights to protect the natural environment, including, for example, protection of threatened or endangered species, prevention of air and water pollution, the right to regulate operations in order to conserve surface resources, the ability to protect historic trails and other cultural and archeological resources, and the right to prevent unnecessary or undue degradation of the public lands.

With respect to onshore oil and gas leasing, management of the leasing program and the resulting leases is entrusted to the United States Bureau of Land Management (BLM) within the United States Department of Interior.[2] For purposes of this Article, I will focus on the retained rights enjoyed by BLM on the public lands and the mineral estate that it manages in the eleven western states. Because of my knowledge of and experience in the State of Wyoming, many of the examples that will be presented relate to Wyoming.

BLM manages approximately 175,000,000 acres of surface estate in the eleven western states, as well as the above-mentioned mineral estate.[3] I will not specifically consider leasing in Alaska in this Article because some different legal provisions apply there, particularly in the National Petroleum Reserve in Alaska, but generally the analysis presented here also applies to BLM-managed oil and gas in Alaska.[4] While the focus of this Article will be on BLM and the lands it manages, similar lines of reasoning and the conclusions that will be presented here also apply to the over 158,000,000 acres managed by the United States Forest Service (Forest Service) in the eleven western states because similar leasing rules apply on those lands.[5] For purposes of this Article, I only consider federal onshore oil and gas leasing and leases. I will not consider offshore leasing managed by the Minerals Management Service under the direction of the Outer Continental Shelf Leasing Act.[6]

In the following sections, I will first describe the Mineral Leasing Act[7] and the onshore oil and gas leasing system it created. I will then discuss the terms and conditions of BLM onshore oil and gas leases with an eye toward what those provisions mean relative to BLM’s retained rights. Following that is a discussion of the retained rights BLM enjoys under applicable laws, lease terms and conditions, regulations, and other authorities a BLM oil and gas lease is made “subject to.” Then I will consider general doctrines of contract law that may also help define BLM’s retained rights. Following that is a discussion of issues that might limit BLM’s exercise of its retained rights, such as Fifth Amendment takings claims. Last, I will consider means by which BLM could exercise its retained rights and policy changes it could make, and then argue that not only does BLM enjoy substantial retained rights, it also has an obligation to assert them.

II. Overview of the Mineral Leasing Act

Onshore leasing of federally owned oil and gas is governed by the Mineral Leasing Act of 1920.[8] The leasing system it established, including provision for royalties to be paid on produced minerals, represented a marked departure from the provisions under the General Mining Law of 1872,[9] where minerals and the exclusive right to possession of the land were granted to the first prospector able to “locate[]” a “valuable” mineral on public lands.[10] The leasing system established by the Mineral Leasing Act for many nonmetalliferous minerals provides for a significant increase in governmental control and regulation of mineral disposition and development compared to the self-initiated system under the General Mining Law that applies to hardrock minerals such as “gold, silver, cinnabar, lead, tin,
[and] copper.”[11]

Subject to enumerated exceptions, the Mineral Leasing Act provides that deposits of coal, phosphate, sodium, potassium, oil, oil shale, gilsonite, or gas, and lands containing such deposits that are owned by the United States, “shall be subject to disposition in the form and manner provided by this chapter.”[12] The Act establishes qualifications for holding an oil and gas lease, establishes limits on the aggregate acreage of lease holdings, allows for cancellation and forfeiture of leases, allows for necessary rules and regulations to be prescribed, provides for royalties and other income to the government and disposition of the moneys received, prescribes the maximum size of individual leases and lease term lengths, and makes many other provisions.[13]

Most significantly for purposes of this Article, section 17 of the Mineral Leasing Act provides for leasing of oil and gas. Section 17(a) declares that “[a]ll lands subject to disposition under this [Act] which are known or believed to contain oil or gas deposits may be leased by the Secretary [of the Interior].”[14] Section 17(b) then provides for a competitive leasing system via oral auction where parcels are leased to the “highest responsible qualified bidder.”[15] If no qualified bids are received at competitive auction, lease parcels become available for sale noncompetitively.[16] Under the provisions for noncompetitive leases, “the person first making application for the lease who is qualified to hold a lease under this [Act] shall be entitled to a lease of such lands without competitive bidding.”[17] In addition to specifying the leasing system, section 17 also makes several provisions related to environmental protection.[18]

This system where leases are first offered at competitive auction before becoming available for noncompetitive sale is relatively new. It was established on December 22, 1987, when the Federal Onshore Oil and Gas Leasing Reform Act (FOOGLRA)[19] was enacted. This law is codified in several sections of the Mineral Leasing Act and elsewhere, but the most important amendments for purposes of this review were the amendments to subsections 17(b) through 17(h), which deal with the leasing provisions that have been mentioned and environmental protection measures that will be described in more detail below.[20] Prior to FOOGLRA a different leasing system existed.

Under the pre-FOOGLRA system, competitive leasing only occurred if a lease was in a “known geologic structure” (KGS).[21] Otherwise, if the lands were not in a KGS, a lease could be acquired on a noncompetitive basis.[22] The noncompetitive system allowed for two ways to acquire a lease.
The first was an over-the-counter purchase based on a first-come, first-served system.[23] The second was based on a lottery system called “SIMO.”[24]
Over-the-counter leases were available if the land was not in a KGS, had never been leased, and the lands had not received bids in the lottery system.[25] The lottery system was utilized for lands not in a KGS but where the lands had been previously leased.[26]

This pre-FOOGLRA leasing system turned out to have a number of problems. BLM had difficulty defining KGSs, which lead to uncertainty and abuse, and outright fraud and speculation occurred in the noncompetitive lottery system.[27] It was these problems that led to the enactment of FOOGLRA and the creation of the modern leasing system where competitive leasing is the general rule and noncompetitive leasing only occurs when a qualified bid is not received at a competitive lease sale.[28] The pre-FOOGLRA leasing system, problems that developed under it, and the resulting enactment of FOOGLRA are ably described in three law review articles[29] and in the leading case of Arkla Exploration Co. v. Texas Oil & Gas Corp.[30]

The significance of the pre-FOOGLRA versus post-FOOGLRA leasing systems is that oil and gas leases have been issued under two distinctly different systems, one in existence before 1987 and one after. However, according to officials with BLM there have been no differences in the terms of a competitive versus a noncompetitive lease, whether issued pre- or post-FOOGLRA.[31] There has been only one lease form in use at any particular time.[32] Thus, when the provisions of BLM leases in use during different time periods are discussed below in an effort to discern BLM’s retained rights, there will be no need to distinguish between competitive- and noncompetitive-issued leases, or—for purposes of ascertaining BLM’s retained rights—a need to distinguish between pre- versus post-FOOGLRA leases.[33]

III. The Federal Onshore Oil and Gas Leasing and Development Process

A. The Stages of BLM Oil and Gas Planning, Leasing, and Development

The BLM onshore oil and gas leasing and development process for federally owned oil and gas is comprised of five steps or stages. These include land-use planning, leasing, exploration, full field development, and filing an application for permit to drill (APD).[34]

1. Land-Use Planning

Step one is land-use planning, the development of BLM Resource Management Plans (RMPs). BLM land-use planning is required under the Federal Land Policy and Management Act (FLPMA).[35] At this stage, lands that will be available for oil and gas leasing are identified, and limitations that will be applied to leasing, including applicable stipulations, are specified.[36] In Wyoming, there are ten BLM field offices and each has an RMP in place.[37] Other western states also have a number of field offices and most operate under the guidance of an RMP.[38] Under many of the RMPs in Wyoming, much of the land under the direction of the field office is available for oil and gas leasing, and this is generally true elsewhere in the West.[39] The development of an RMP requires compliance with the National Environmental Policy Act (NEPA)[40] and is therefore accompanied by preparation of an environmental impact statement (EIS).[41]

2. Leasing

The next stage in the oil and gas leasing and development process on BLM lands and mineral estates is the leasing stage. At this stage leases are first offered for sale at competitive auctions and then are available noncompetitively if a qualified bid is not received at the competitive sale.[42] After an acceptable offer is received, and assuming there are no protests that delay the leasing process, a lease is issued.[43] As has been recognized in numerous court and administrative decisions, the leasing stage is crucial because it represents an “‘irreversible and irretrievable commitment[] of resources’” due to the developed rights granted by a federal onshore oil and gas lease, and thus compliance with NEPA is required prior to issuing a lease, at least when the lease does not contain a stipulation specifying there will be no surface occupancy of the leasehold.[44] This issue will be discussed in more detail in Part VII.D.

3. Exploration

Once an oil and gas lease is issued, the next step is often exploration to determine if there are likely to be valuable oil and gas deposits on a lease. BLM has developed regulations that govern exploration, and exploration projects are also subject to NEPA.[45] In general, at least in Wyoming, exploration projects are approved by preparation of a NEPA environmental assessment (EA), not a more detailed EIS.[46] Sometimes a leaseholder does not engage in exploration and proceeds directly to drilling a “wildcat” well, so called because the well is drilled in an area where the potential for production in paying quantities is uncertain.[47]

4. Full-Field Development

If it becomes apparent that oil and gas may be present in an area and that a number of wells are likely to be drilled, the process enters what is called the project level stage. This stage is also sometimes called the
“full-field development” stage.[48] NEPA applies to this level of activity because of the BLM approvals required before development can occur, and often an EIS is prepared (sometimes an EA is prepared for smaller fields or drilling projects).[49] There have been a number of full-field development EISs prepared in Wyoming in recent years, including, but by no means limited to, analyses of the Jonah Infill project, the Pinedale Anticline project, the Atlantic Rim project, and coal bed methane development in the Powder River Basin; these EISs can be reviewed on BLM field office websites.[50] Approval of these projects through the “record of decision” that accompanies an EIS can allow for the drilling of thousands of wells.[51] Similar full field development EISs in environmentally significant areas have been developed in several of the other western states in recent years, such as the Roan Plateau project in western Colorado.[52]

5. Application for Permit to Drill

Finally, the last stage in the oil and gas development process on BLM lands and mineral estates is called the APD stage. Under BLM’s regulations, no well can be drilled until an APD has been approved.[53] Up until now, no actual surface disturbance has occurred (other than the relatively limited disturbance associated with exploration), but after the APD stage, drills can begin to dig into the ground.[54] The APD stage also implicates NEPA, and in many cases an EA is prepared as part of the APD approval to ensure environmental concerns are considered and mitigated on a site-specific basis.[55] However, since passage of the Energy Policy Act of 2005,[56] “categorical exclusions” from NEPA compliance at the APD stage have been available in many cases, and NEPA compliance at the APD stage has been made less rigorous.[57] In addition to complying with NEPA, the Mineral Leasing Act provides that when an APD is filed, BLM must provide notice to the public of the proposed action.[58]

The outcome of this multistage oil and gas leasing and development process can be substantial environmental disturbance, such as the thousands of wells that have been planned and drilled in Wyoming’s Pinedale Anticline and Jonah fields, and in the Powder River Basin.[59] Similar levels of activity are apparent in other parts of the West, such as in the Farmington area in New Mexico, the Piceance Basin in Colorado, the Uinta Basin in Utah, and in Montana’s portion of the Powder River Basin.[60] It is this Article’s premise that to prevent substantial environmental harm in these and many other environmentally significant areas, it is crucial that BLM recognize the retained rights it still enjoys despite having issued an oil and gas lease and regulate this development accordingly.

B. The BLM Onshore Oil and Gas Leasing Process

Numerous provisions that govern oil and gas leasing can be found in the Mineral Leasing Act and in BLM’s oil and gas leasing regulations.[61]
For purposes of this Article it is not necessary to provide a detailed discussion of the leasing process, but some relevant provisions will be mentioned in this section. A user-friendly description of the leasing process can be found on the BLM website.[62] Information on particular lease sales can be found on BLM state office web pages.[63]

As mentioned, there are two means by which BLM can offer onshore oil and gas leases. Leases must first be made available for sale at a competitive oil and gas auction, which are held at least quarterly.[64] If no legally sufficient bids are received at the competitive sale, BLM can then make the leases available on a noncompetitive basis.[65] Leases not sold at a competitive oil and gas lease sale remain available for noncompetitive leasing for a period of two years after the competitive lease sale.[66]

The maximum size of a competitive lease parcel is 2560 acres (different limits apply in Alaska) and the maximum size of a noncompetitive parcel is 10,240 acres.[67] The primary term of a lease is for ten years and the lease will automatically continue in force so long as there is at least one well on the lease capable of producing oil and gas in paying quantities, or the lease has been committed to a “unitized” group of leases that have at least one well capable of producing in paying quantities.[68] A lease term can be extended for two years if actual drilling is being diligently prosecuted prior to the end of the primary term.[69]

The annual rental on a lease is $1.50 per acre, or fraction thereof, for the first five years of the lease and $2.00 per acre thereafter.[70] Royalties on production must be paid at a rate of 12.5% of the value of production removed.[71] Royalties and other monies received are paid to the United States Department of the Treasury, with fifty percent of that returned to the state where the oil or gas was produced.[72] In addition to rent and royalties, bonding is required prior to conducting surface disturbing activities to ensure compliance with lease terms and reclamation and restoration of impacted lands.[73] Bonding must be in an amount not less than $10,000 per lease or, in lieu of that, statewide bonds of $25,000 or nationwide bonds of $150,000 can be posted.[74]

Generally, BLM will issue a lease to a successful bidder after it receives the bid form and all money due.[75] A lease is effective the first day of the month following the month in which BLM signs the lease, although there are provisions allowing for the lease to be effective sooner.[76] However, the public can protest the sale of leases.[77] If this is done—and BLM often receives protests of lease parcels offered for sale at auction—the lease will not be issued until the protest is resolved, which often takes several months.[78] If the protest is rejected, BLM can issue the lease.[79] If a protest is upheld, the lease parcel will be withdrawn and fees, rentals, and bonus bids will be returned to the bidder.[80] However, a BLM decision to reject a protest is subject to appeal to the Interior Board of Land Appeals (IBLA).[81]

A BLM oil and gas lease issued as a result of this leasing process is made subject to a number of provisions and it also contains a number of terms. The next Part of this Article will discuss these terms and how they create an array of retained rights for BLM, allowing it to regulate oil and gas development in order to protect the natural environment.

IV. The Terms and Conditions of BLM Onshore Oil and Gas Leases

The place to start in determining what rights BLM retains when it issues an onshore oil and gas lease is with the lease itself, the contractual agreement the government enters into when it issues a lease to a private party. BLM’s current regulations provide that “[a] lease shall be issued only on the standard form approved by the Director [of BLM].”[82]

A. Versions of the BLM Oil and Gas Lease Form

Over the years since the Mineral Leasing Act was enacted in 1920, BLM has used several lease forms to issue leases under the pre-FOOGLRA and post-FOOGLRA leasing frameworks. Currently, BLM leases are presented on Form 3100-11, the “Offer to Lease and Lease for Oil and Gas.”[83] Based on information received from BLM’s Forms Manager in Denver, five versions of Form 3100-11 were used between 1984 and 2006.[84] There were no earlier versions of the form on file. The earliest version of Form 3100-11 is dated March 1984.[85] Later versions dated June 1988, October 1992, February 2003, and July 2006 were also on file.[86] In October 2008, BLM adopted a further revision to Form 3100-11, and this is now the most recent version of the standard lease form.[87] Thus, six versions of Form 3100-11 may apply to leases in existence today.

Despite the lack of earlier versions of the lease form that are on file in the BLM archives, upon request I received three examples of earlier leases from the BLM Wyoming state office.[88] These leases were issued in 1954, 1965, and 1971.[89] This sampling of older lease forms coupled with the six archived versions of Form 3100-11 likely constitute a reasonably complete picture of lease forms that have been used over the years, allowing an analysis of what rights have been retained by BLM when it issues an oil and gas lease.
The nine lease forms considered in this Article are on file with the author and are available upon request. In addition, the version of Form 3100-11 currently in use—the October 2008 form—is available via the hyperlink referenced in footnote 83.

 

Table 1: Number of Currently Active Federal Oil and Gas Leases in the Eleven Western States Issued During the Indicated Time Period when Various BLM Oil and Gas Lease Forms Were in Effect or
Presumed to Have Been in Effect
[90]

 

Date Lease Form Was Made Effective

Period of Time Lease Form Was in Effect or
Is Presumed to
Have Been in Effect

Number of Still-Active Leases in the Eleven Western States Issued During This Time Period

September 1953

1920–1954[91]

4383

August 1961

1955–1965[92]

1948

May 1968

1966–February 1984[93]

6755

March 1984

March 1984–May 1988[94]

889

June 1988

June 1988–September 1992

1113

October 1992

October 1992–January 2003

11,442

February 2003

February 2003–June 2006

13,819

July 2006

July 2006–September 2008

6469

October 2008

October 2008–Present

1524

TOTAL

48,342

 

Working from these lease forms, I have assessed the number of leases that are currently active in the eleven western states that were issued in the time periods when the various versions of the leases were in effect or when it is presumed the lease forms were in effect—i.e., the 1954, 1965, and 1971 lease examples have presumed periods of effectiveness; the period when a lease form was in effect is certain with respect to the six 3100-11 forms that have been archived since 1984. Table 1 presents the results of this analysis.[95]

Knowing how many still-active leases were issued during the time periods when each version of the lease was in effect or is presumed to have been in effect allows an analysis of what terms and conditions of a lease were effective at various times and thus allows consideration of what rights have been retained by BLM. While the varying periods when different lease forms were in effect or presumed to have been in effect makes it impossible to discern if there were periods of time when greater rates of leasing were occurring, it is apparent the majority of currently active leases were issued since 1984 when the best records of operative lease forms are available.

B. The Terms of Federal Onshore Oil and Gas Leases

The nine lease forms all start from the proposition that the federal government is granting the lessee the exclusive right to fully develop any oil and gas that may be found on the leasehold and that any necessary facilities that are required to extract the oil and gas can be constructed.[96] The 1954 lease states,

The lessee is granted the exclusive right and privilege to drill for, mine, extract, remove, and dispose of all the oil and gas deposits, except helium gas, in the lands leased, together with the right to construct and maintain thereupon, all . . . structures necessary to the full enjoyment thereof.[97]

The 1965 and 1971 leases make the same provision.[98] Beginning with the March 1984 lease form it is stated that “[t]his lease is issued granting the exclusive right to drill for, mine, extract, remove and dispose of all the oil and gas (except helium) in the lands described . . . together with the right to build and maintain necessary improvements thereupon.”[99] This same language is contained in the June 1988, October 1992, February 2003,
July 2006, and October 2008 lease forms.[100]

But in all of these lease forms the government also retains a number of rights allowing it to condition development so as to protect the environment. In the 1954 lease form, the lease is made “subject to” the provisions of the Mineral Leasing Act and reasonable regulations not inconsistent with the terms of the lease and the provisions in the lease.[101] The lessee agrees to a number of terms and the lessor reserves several rights. The lessee agrees “[t]o take such reasonable steps as may be needed to prevent operations from unnecessarily” causing or contributing to soil erosion or damaging forage or timber growth, polluting waters, damaging crops, or damaging range improvements.[102] It is also agreed that upon conclusion of operations the lessee will restore the surface to its former condition, and the lessor is permitted to prescribe the steps and restoration to be made.[103] The lessee further agrees that rental and royalty suspension may occur if the Secretary of the Interior finds such is necessary “for the purpose of encouraging the greatest ultimate recovery of oil or gas and in the interest of conservation of natural resources.”[104] Moreover, the lessee agrees to “plug properly and effectively all wells . . . before abandoning the same.”[105] Perhaps most significantly, it is agreed in section 4 of the 1954 lease

that the rate of prospecting and developing and the quantity and rate of production from the lands covered by this lease shall be subject to control in the public interest by the Secretary of the Interior, and in the exercise of his judgment the Secretary may take into consideration, among other things, Federal laws, State laws, and regulations issued thereunder.[106]

The lessor also reserved the right to dispose of the surface of the leased lands if not necessary for the extraction of the oil and gas and the right “to dispose of any resource in such lands” if it would not “unreasonably interfere” with lease operations.[107]

The 1965 lease provides that the lease is subject to the same conditions, that the lessee agrees to the same provisions, and that lessor has the same reserved rights.[108] The 1971 lease, too, makes these provisions, but the agreement to not unnecessarily damage enumerated natural resources is expanded to include agreeing not to pollute the air as well as water, and to protecting fossil, historic, or prehistoric resources and other antiquities that are found.[109]

Beginning with the March 1984 lease form, the form takes on what might be called its modern form, and it will be referred to as such henceforth.[110] Many of the provisions in the 1954, 1965, and 1971 leases are continued, but often in somewhat modified form. In this modern form, following the statement of what the lease grants—the exclusive right to extract all of the oil and gas on a leasehold—there immediately follows a statement of what the lease is made “subject to.” The lease states,

Rights granted are subject to applicable laws, the terms, conditions, and attached stipulations of this lease, the Secretary of the Interior’s regulations and formal orders in effect as of lease issuance, and to regulations and formal orders hereafter promulgated when not inconsistent with lease rights granted or specific provisions of this lease.[111]

This same statement is made in the June 1988, October 1992,
February 2003, July 2006, and October 2008 lease forms.[112]

There are several relevant lease terms in the modern lease form that the rights granted to the lessee are made subject to. In section 2 the provision allowing suspension of royalties is maintained. But now, rather than being available “for the purpose of encouraging the greatest ultimate recovery of oil or gas and in the interest of conservation of natural resources,”[113] this action can be taken when necessary “to encourage the greatest ultimate recovery of the leased resources, or [as] is otherwise justified.”[114]
The agreement to allow the Secretary of the Interior to specify the rate of development is maintained but is slightly modified in section 4 of the modern lease forms: “Lessor reserves right to specify rates of development and production in the public interest . . . if deemed necessary for proper development and operation of area, field, or pool embracing these leased lands.”[115] In section 7 of the modern lease forms it is stated that if the impacts from mining “would be substantially different or greater” than normal, “lessor reserves the right to deny approval of such operations.”[116] And in section 12 it is provided that when the leased lands are returned to the lessor, the lessee will reclaim the land as specified by the lessor and remove equipment and improvements not deemed necessary by the lessor for the preservation of producible wells.[117] These same provisions are made in all of the modern lease forms.

But the most significant term in the modern lease forms relative to retained rights allowing protection of the natural environment is section 6 of the lease form. In the March 1984, June 1988, October 1992, and February 2003 forms, this term provides the following:

Lessee shall conduct operations in a manner that minimizes adverse impacts to the land, air, and water, to cultural, biological, visual, and other resources, and to other land uses or users. Lessee shall take reasonable measures deemed necessary by lessor to accomplish the intent of this section. To the extent consistent with lease rights granted, such measures may include, but are not limited to, modification to siting or design of facilities, timing of operations, and specification of interim and final reclamation measures. Lessor reserves the right to continue existing uses and to authorize future uses upon or in the leased lands, including the approval of easements or rights-of-way. Such uses shall be conditioned so as to prevent unnecessary or unreasonable interference with rights of lessee.[118]

Section 6 goes on to provide that prior to any surface disturbance, “lessee shall contact lessor to be apprised of procedures to be followed
and modifications or reclamation measures that may be necessary.”[119]
This section allows for inventories and studies “to determine the extent of impacts to other resources,” although these apparently are limited to “minor inventories” or “short term special studies.”[120] Section 6 concludes by requiring that if during the conduct of operations “threatened or endangered species, objects of historic or scientific interest, or substantial unanticipated environmental effects are observed, lessee shall immediately contact the lessor” and “shall cease any operations that would result in the destruction of such species or objects.”[121] As indicated, these provisions appeared in the March 1984 through February 2003 lease forms; however, the July 2006 and October 2008 lease forms changed the language in Section 6.[122]

In the July 2006 and October 2008 versions of the lease, where previously the word “shall” had been used in section 6 it was replaced with the word “must.”[123] So, for example, the prior requirement that lessee “shall” conduct operations so as to minimize adverse impacts was changed to a requirement that lessee “must” conduct operations to minimize such impacts.[124] And the former requirement that lessee “shall” take reasonable measures deemed necessary by lessor to accomplish this intent was replaced with a statement that lessee “must” take reasonable measures so as to accomplish the intent of minimizing adverse impacts.[125]

The significance of this wording change may be debatable but is probably minimal. In construing the word shall, the United States Supreme Court offered that “[t]hough ‘shall’ generally means ‘must,’” the use, or misuse, of the word “shall” was apparent in the usage of some legal writers because they posited less-than-mandatory definitions of “shall.”[126] “Must” means to “be obliged or required by morality, law, or custom,”[127] and “shall” means something that will take place or exist in the future or an order, promise, requirement, or obligation.[128] Black’s Law Dictionary states that “must,” “like the word ‘shall,’ is primarily of mandatory effect,”[129] and that shall “is generally imperative or mandatory.”[130] It goes on to state that “shall” “in ordinary usage means ‘must’ and is inconsistent with a concept of discretion.”[131] Standard works presenting the meaning of words as construed by the courts also indicate that “shall” and “must” are generally construed in a mandatory light.[132]

It is apparent from the nine versions of the lease reviewed that BLM has retained substantial rights allowing it to protect the natural environment despite having granted lessees a right to develop the oil and gas that might be found on a lease. The leases issued prior to 1984 appear to retain somewhat fewer or lesser rights than those issued after 1984, but even in these earlier leases the lessee agreed “[t]o take such reasonable steps” as are needed to prevent certain categories of resource damage.[133] And probably most significantly it was agreed by BLM and the lessee

that the rate of prospecting and developing and the quantity and rate of production . . . shall be subject to control in the public interest by the Secretary of the Interior, and in the exercise of his judgment the Secretary may take into consideration, among other things, Federal laws, State laws, and regulations issued thereunder.[134]

After March 1984, section 6 of the lease form required that in the conduct of operations, the lessee was required to minimize adverse impacts to a number of resources and specified that reasonable measures deemed necessary by lessor could be specified to ensure this was accomplished, so long as consistent with the lease rights granted.[135] These reasonable measures could include, but were not limited to, modifications to the siting or design of facilities, timing of operations, and the specification of interim and final reclamation measures.[136] The modern lease forms continued to specify that the “[l]essor reserves the right to specify rates of development and production in the public interest.”[137] In the modern leases, the entire lease is made “subject to” applicable laws; the terms, conditions, and stipulations of the lease; the regulations and formal orders that are in place when the lease is issued; and later-adopted regulations and formal orders, if not inconsistent with the lease rights granted.[138] So again, all lease forms have retained a number of rights to the government that allow it to substantially protect the natural environment despite having issued a lease that grants the “exclusive right” to remove all of the oil and gas that might be found on a leasehold.

C. BLM’s 43 C.F.R. § 3101.1-2 Regulation

Another important determinant of what rights and limitations have been created under a BLM onshore oil and gas lease besides the terms and conditions in the standard lease form are the provisions in the BLM leasing regulation found at 43 C.F.R. § 3101.1-2.[139] In this Part I will first present the language of the § 3101.1-2 regulation, then discuss its “reasonable measures” provision which mirrors that in section 6 of the modern lease form, and follow that with a consideration of further BLM guidance interpreting the § 3101.1-2 regulation.

1. The Provisions of the § 3101.1-2 Regulation

This regulation in its current form was promulgated on May 16, 1988.[140] Consequently, this regulation would not specifically or necessarily have been made applicable to leases issued prior to May 1988. But, as Table 1 shows, only twenty-nine percent of the leases that are currently in effect in the eleven western states were issued before this regulation was promulgated and seventy-one percent were issued after its adoption. The regulation provides in full that

[a] lessee shall have the right to use so much of the leased lands as is necessary to explore for, drill for, mine, extract, remove and dispose of all the leased resource in a leasehold subject to: Stipulations attached to the lease; restrictions deriving from specific, nondiscretionary statutes; and such reasonable measures as may be required by the authorized officer to minimize adverse impacts to other resource values, land uses or users not addressed in the lease stipulations at the time operations are proposed. To the extent consistent with lease rights granted, such reasonable measures may include, but are not limited to, modification to siting or design of facilities, timing of operations, and specification of interim and final reclamation measures.
At a minimum, measures shall be deemed consistent with lease rights granted provided that they do not: require relocation of proposed operations by more than 200 meters; require that operations be sited off the leasehold; or
prohibit new surface disturbing operations for a period in excess of 60 days in
any lease year.[141]

In addition, BLM’s regulations define the term “operating right,” which is “the interest created out of a lease authorizing the holder of that right to enter upon the leased lands to conduct drilling and related operations, including production of oil or gas from such lands in accordance with the terms of the lease.”[142]

2. Reasonable Measures

In addition to making a lease subject to stipulations and specific, nondiscretionary statutes, issues that will be addressed below,[143] the § 3101.1-2 regulation provides that “reasonable measures” may be required so as to minimize adverse impacts to the environment and other resources.[144] So long as consistent with the lease rights granted, these reasonable measures may include, “but are not limited to,” modification to siting and design of facilities, timing of operations, and specification of reclamation measures.[145] Given that modern versions of the lease form make these same provisions in section 6, it seems unlikely that “reasonable measures” that might be demanded would be inconsistent with the lease rights granted, so long as any oil and gas can still be extracted. And the term in older leases specifying that the rate of prospecting and development is subject to control “in the public interest” does not indicate that reasonable measures could not be required of operations on these older leases as well.

The provisions in the § 3101.1-2 regulation and section 6 of the modern lease appear to be complimentary and should be read together. However, the § 3101.1-2 regulation may attempt to shrink the potential scope of reasonable measures by providing that

[a]t a minimum, [reasonable] measures shall be deemed consistent with lease rights granted provided that they do not: require relocation of proposed operations by more than 200 meters; require that operations be sited off the leasehold; or prohibit new surface disturbing operations for a period in excess of 60 days in any lease year.[146]

This provision, often called the “200-meter 60-day rule,” is sometimes cited as a limit to BLM’s ability to condition development. BLM or lessees sometimes claim that, in the absence of a stipulation or specific, nondiscretionary statute, the only “reasonable measures” that can be imposed are those in compliance with the 200-meter 60-day “rule.”[147]
This restricted view of the regulation is unwarranted.

For one thing, the regulation is specific that these limited measures, which have been defined as consistent with the lease rights granted and thus are “reasonable,” are “a minimum” of what is consistent with lease rights.[148] Moreover, the final rulemaking, which addressed comments in response to the proposed rule about the definition of “reasonable measures,” clarifies the meaning of “reasonable” in the context of the § 3101.1-2 regulation.[149]
BLM stated, “The final rulemaking provides that the Bureau, at a minimum, can require relocation of proposed operations by 200 meters and can prohibit new surface disturbance for a period of 60 days, and that such requirements are consistent with the lease rights granted.”[150] BLM then stated that “the authority of the Bureau to prescribe ‘reasonable,’ but more stringent, protection measures is not affected by the final rulemaking.”[151]

Quite simply, the 200-meter 60-day rule establishes a floor, not a ceiling, as to the reasonable measures BLM may require. The specific terms in section 6 of the standard lease form certainly do not limit BLM’s authority to just require reasonable measures that comply with the 200-meter 60-day rule, which the lease contract does not even mention. It may be worth noting that the modern version of the lease form—specifically the March 1984 version—predated the § 3101.1-2 regulation by at least four years, so BLM certainly developed the May 1988 § 3101.1-2 regulation in recognition of the existing provisions in its lease form that were in use at the time, namely those in section 6, which do not limit reasonable measures to just those stated in the 200-meter 60-day rule.[152]

In considering supplemental mitigation measures required by BLM to protect the greater sage-grouse (Centrocercus urophasianus), the Interior Board of Land Appeals (IBLA) rejected an interpretation of the § 3101.1-2 regulation that would not allow reasonable measures beyond those mentioned in the 200-meter 60-day rule.[153] It stated, “[This] constrained interpretation of a ‘reasonable measure’ is at odds with the plain language of the regulation, which describes what measures ‘at a minimum’ are deemed consistent with lease rights, and does not purport to prohibit as unreasonable per se measures that are more stringent.”[154] What is reasonable should be determined by what is needed to minimize adverse impacts while still allowing access to any oil and gas, not the predetermined minimum limits mentioned in the 200-meter 60-day rule.

3. Further BLM Guidance on the § 3101.1-2 Regulation

After issuing the § 3101.1-2 regulation, BLM determined there was potential for confusion and disagreement about how the § 3101.1-2 regulation should be interpreted. In an Instruction Memorandum (IM) issued on December 3, 1991, BLM attempted to clarify the requirements of the § 3101.1-2 regulation.[155] Using the term “reserved authority,” BLM stated that “[w]ithin this . . . authority, the BLM may impose additional mitigation measures [beyond stipulations] to ensure that proposed operations minimize adverse impacts to other resources” so long as consistent with lease rights granted.[156] More specifically, BLM determined that the requirement in the Federal Land Policy and Management Act of 1976 for BLM to “take any action necessary to prevent unnecessary or undue degradation of the [public] lands”[157] served as a basis to require reasonable measures in excess of the 200-meter 60-day rule.[158] Approaching imposition of reasonable measures through use of this FLPMA standard was seen as placing
“the resolution of this issue clearly within the concept of striking the best multiple use balance.”[159] However, BLM then went on to narrow the application of this FLPMA statutory standard by imposing a requirement that the need for any reasonable measures required to comply with the unnecessary or undue degradation clause must be “clearly and convincingly documented” based on a site-specific analysis.[160]

Under the terms of IM 92-67, its provisions were to be incorporated into BLM Manual MS-3101, and BLM has done this.[161] The manual generally restates the language from the IM, providing that, among other things, “[t]he clear evidence and convincing need” for conditions of approval must be demonstrated on a site-specific basis.[162] And, as was true in the IM, this requirement was focused on providing for compliance with FLPMA unnecessary or undue degradation clause, not any other statutory requirements.

The requirement for clear and convincing evidence made in the IM and the BLM manual creates an unwarranted hurdle for BLM’s exercise of its authority to require reasonable measures. The § 3101.1-2 regulation states that the basis for imposing reasonable measures is “to minimize adverse impacts to other resource values.”[163] This language is directly comparable to the language in section 6 of the standard lease form, which provides that the lessee shall (or must) conduct operations so as to minimize adverse impacts.[164] Moreover, the § 3101.1-2 regulation and section 6 of the lease form recognize modifications to facility siting and design and timing of operations are means to accomplish these reasonable measures, but options “are not limited to” these measures.[165] The § 3101.1-2 regulation also explicitly states that the enumerated 200-meter 60-day rule provisions are “[a]t a minimum” of what is consistent with the lease rights. In the final rule adopting the § 3101.1-2 regulation, BLM stated, “[T]he authority of the Bureau to prescribe ‘reasonable,’ but more stringent, protection measures is not affected by the final rulemaking.”[166] Nowhere, other than in the IM and manual, is it indicated that the basis for imposing a reasonable measure that exceeds the 200-meter 60-day rule is found only in assuring compliance with the unnecessary or undue degradation clause of the FLPMA, and more importantly there is no indication the standard of proof should be the heightened clear and convincing evidence test specified in the IM and manual.

IBLA recently recognized BLM’s rights to condition postlease development pursuant to the § 3101.1-2 regulation and the unnecessary or undue degradation clause, holding that BLM could require post-lease conditions of approval that were not addressed in lease stipulations to protect sage-grouse.[167] IBLA determined that a claim that conditions of approval were limited to no more than the limits in the 200-meter 60-day rule was unsupported by the § 3101.1-2 regulation and that more stringent limitations were not inconsistent with lease rights.[168] In reaching this conclusion, IBLA did not mention any need for clear and convincing evidence to support BLM’s decision to require more stringent mitigation to protect the sage-grouse.[169] Accordingly, there is no underlying basis for requiring clear and convincing evidence before a reasonable measure can be required.[170]

D. Summary of Rights Granted and Rights Retained Under the Modern Lease Form and the § 3101.1-2 Regulation

The § 3101.1-2 regulation expands on or elaborates on the rights that have been granted pursuant to a BLM oil and gas lease and provides further definition of what rights have been retained by BLM. If read with the provisions in the modern version of the standard lease form, it is apparent that three rights are granted pursuant to a BLM onshore oil and gas lease: 1) an “exclusive right” to remove all of the oil and gas on the leasehold;[171] 2) the right to “use” as much of the leasehold as is “necessary” to recover all of the leased resource;[172] and 3) the right to build and maintain “necessary” improvements to extract the leased resource.[173] Thus, the lessee has a right to exclude others from developing the lease during his removal of all of the oil and gas that might be found on the lease, a right to use no more of the lease than is “necessary” to retrieve all of the leased oil and gas, and a right to build only “necessary” improvements. Lessees have not been granted a right to develop the oil and gas in exactly the place they desire, the manner they desire, or on the exact timeline they may desire.

Conversely, when the § 3101.1-2 regulation is considered with the terms and conditions in the standard lease form operative since 1984, it is apparent BLM has retained a number of rights allowing it to limit or condition development. Under the modern versions of the standard lease form in effect since 1984 and the § 3101.1-2 regulation in effect since 1988, BLM has made development of the lease and removal of any oil and gas “subject to” a number of provisions that allow BLM to condition development, including the following:

  • Applicable laws;[174]
  • Terms, conditions, and stipulations in the lease;[175]
  • Regulations and formal orders in effect when the lease is issued;[176]
  • Regulations and formal orders issued afterward, if not inconsistent with lease rights granted and specific provisions in the lease;[177]
  • Specific, nondiscretionary statutes;[178] and
  • Reasonable measures.[179]

This constellation of rights granted and rights retained that are stated in the lease contract and in the regulatory provision largely define the scope and nature of BLM’s retained rights. As will be discussed next, these rights allow BLM to substantially protect the natural environment when oil and gas development is proposed on an onshore oil and gas lease.

V. BLM’s Retained Rights Under a Federal Onshore Oil and Gas Lease

Under the terms of the modern lease form and the 43 C.F.R. § 3101.1-2 regulation, BLM retains several rights because the lease is made “subject to” these reservations of authority. The lease rights granted are subject to: applicable laws; terms, conditions, and stipulations of the lease; regulations and formal orders in effect when the lease is issued; regulations and formal orders issued afterward, if not inconsistent with lease rights granted or provisions in the lease; stipulations attached to the lease; specific, nondiscretionary statutes; and reasonable measures that BLM might require.[180] While older leases may not as clearly have been made subject to these conditions, the rights granted in those leases are also conditioned to a significant degree.

In this Part, after a brief review of the Supreme Court’s view of the rights retained under a federal onshore oil and gas lease, I will review each of the conditions on the right to develop oil and gas. Based on this review, it will be clear BLM has very substantial retained rights that allow it to regulate oil and gas development so as to protect the natural environment.

A. The Supreme Court’s View of the Rights Granted and Rights Retained Under a Federal Onshore Oil and Gas Lease

The scope of retained rights under a federal onshore oil and gas lease was outlined many years ago by the Supreme Court in Boesche v. Udall,[181] where the Court stated:

Unlike a land patent, which divests the Government of title, Congress under the Mineral Leasing Act has not only reserved to the United States the fee interest in the leased land, but has also subjected the lease to exacting restrictions and continuing supervision by the Secretary. . . . [The Secretary] may prescribe, as he has, rules and regulations governing in minute detail all facets of the working of the land. In short, a mineral lease does not give the lessee anything approaching the full ownership of a fee patentee, nor does it convey an unencumbered estate in the minerals.[182]

Accordingly, it is clear BLM has very expansive retained rights under a federal onshore oil and gas lease that allow it to condition development so as to protect natural resources and values. The recognition by the Supreme Court of these expansive rights retained by the government occurred long before the modern lease form was put in place in 1984 with its explicit list of authorities a lease is made “subject to.”

B. Applicable Laws and Specific, Nondiscretionary Statutes

Modern leases issued since March 1984 are made subject to “applicable laws” under the terms of the lease form.[183] In addition, leases issued since May 1988 are made subject to “restrictions deriving from specific, nondiscretionary statutes” under the terms of the § 3101.1-2 regulation.[184] “Applicable laws” would seem to be a category of statutes the lease has been made subject to that is broader than “specific, nondiscretionary statutes.”
I believe that both of these provisions guide what retained rights BLM enjoys, not one to the exclusion of the other, at least with regard to the 34,367 currently active leases in the eleven western states issued since June 1988, when both reservations were in place (see Table 1).

BLM’s commentary when it adopted the § 3101.1-2 regulation indicates it was not the intent of this regulation to replace or supplant the “applicable laws” language in the lease form.[185] While the commentary focuses on the “reasonable measures” language in the regulation, the overall thrust of this regulation was to “establish the measures over which the Bureau has clear authority” and to “establish minimum parameters” for purposes of specifying site-specific mitigation measures.[186] Consequently, the “specific, nondiscretionary statute” language in the regulation is probably best interpreted as setting a baseline from which BLM has “clear authority,” and not an attempt to exclude other applicable laws that are perhaps less mandatory. Furthermore, BLM’s leasing regulations provide that “[a] lease shall be issued only on the standard form approved by the Director” of BLM.[187] This regulation was also adopted on May 16, 1988, when the current version of the § 3101.1-2 regulation was adopted,[188] so it seems unlikely BLM was attempting to nullify the “applicable laws” language that was already in its existing lease forms through use of the “specific, nondiscretionary statutes” language in the § 3101.1-2 regulation. The “applicable laws” language was present in leases from March 1984 onward, so if BLM intended to modify or limit this language in the § 3101.1-2 regulation adopted in
May 1988 it would have done so explicitly.

Because I view most currently active leases as being subject to both applicable laws and specific, nondiscretionary statutes, I will review both of these kinds of laws. Myriad laws are applicable to environmental protection on a leasehold, and there are several statutes that are specific and nondiscretionary. Some of these laws have been in place for many years—one was enacted prior to the Mineral Leasing Act—and thus would apply to all or most active leases.[189] Many were enacted in the 1960s and 1970s, and thus would have been laws in place when both the “applicable laws” language was introduced in March 1984 and when the “specific, nondiscretionary statutes” language was introduced in May 1988.[190] Thus, many of the laws that will be discussed below at a minimum help define BLM’s retained rights on the 35,256 out of 48,342 currently active leases in the eleven western states that have been issued since March 1984 (see Table 1).[191]

1. The Mineral Leasing Act

As discussed, the Mineral Leasing Act provides for the “disposition” of oil and gas through a leasing system.[192] The Mineral Leasing Act also contains several other provisions that are applicable to oil and gas development that implicate environmental protection, and one provision appears to be specific and nondiscretionary.

First, “[e]ach lease shall contain provisions for the purpose of insuring the exercise of reasonable diligence, skill, and care in the operation of said property.”[193] The courts do not appear to have interpreted the meaning of the word “care” in this passage, but it could allow for protection of the natural environment in the operation of a lease.[194] Second, “[t]he Secretary of the Interior is authorized to prescribe necessary and proper rules and regulations and to do any and all things necessary to carry out and accomplish the purposes of this [Act], also to fix and determine the boundary lines of any structure, or oil or gas field.”[195] The courts have recognized this provision grants broad authority to the Secretary of the Interior to regulate oil and gas development.[196] It obviously allows great discretion in rulemaking, and the regulations applicable to oil and gas leasing and lease operations will be discussed below.[197] But the additional authority to “determine the boundary lines of any structure, or oil or gas field”[198] could directly allow for environmental protection by authorizing BLM to specify the locations of structures and oil and gas fields. A third reservation of authority provided by the Mineral Leasing Act is that “[t]he Secretary of the Interior, for the purpose of encouraging the greatest ultimate recovery of [leasable minerals], and in the interest of conservation of natural resources, is authorized to waive, suspend, or reduce the rental, or minimum royalty, or reduce the royalty on an entire leasehold.”[199] In Copper Valley Machine Works, Inc. v. Andrus[200] and Getty Oil Co. v. Clark,[201] the courts recognized and approved the government’s authority to suspend leases so as to conserve environmental resources based on this statutory provision.[202]

And in what is likely a specific, nondiscretionary provision, the Mineral Leasing Act requires that “[t]he Secretary of the Interior . . . shall regulate all surface-disturbing activities conducted pursuant to any lease issued under this chapter, and shall determine reclamation and other actions as required in the interest of conservation of surface resources.”[203] This addition to the Mineral Leasing Act was adopted in 1987 in the Federal Onshore Oil and Gas Leasing Reform Act (FOOGLRA).[204] Accordingly, this provision may only create retained rights on leases issued after 1987. But even if this is true, approximately 34,367 of the 48,342 currently active leases in the eleven western states are subject to this provision (see Table 1).

2. The National Environmental Policy Act

Although it is well settled that NEPA does not mandate particular results to protect the environment but rather prescribes the necessary process for environmental review, NEPA is also referred to as our nation’s basic environmental charter.[205] NEPA provides that “to the fullest extent possible” the laws and policies of this country are to be interpreted and administered in accordance with the policies set forth in NEPA, which include environmental protection goals.[206] In carrying out the policy of NEPA, agencies must “use all practicable means” consistent with other considerations of national policy to achieve six specified ends aimed at environmental protection.[207] The Council on Environmental Quality regulations implementing NEPA reinforce the obligation to pursue protection of the natural environment that NEPA mandates.[208]

While NEPA may not be specific and nondiscretionary, there is no doubt it is applicable to oil and gas development decision making on BLM lands. The prominent role NEPA plays at the leasing stage will be discussed infra in Part VII.D. However, the courts also recognize that the purposes and goals of NEPA control BLM’s oil and gas development decisions.
In Getty Oil Co., the court determined that “[t]he Secretary [of the Interior] is not only permitted, but is required, to take environmental values into account in carrying out his regulatory functions [related to oil and gas development], unless there is a clear and unavoidable statutory authority prohibiting the Secretary from complying with NEPA’s mandate.”[209]

In a case originating in an important natural area in Michigan that included brown trout (Salmo trutta) waters described as perhaps
“the best east of the Rockies,” the court considered BLM’s and the
Forest Service’s obligations under NEPA when lease development activities are pursued, in this case approval of exploratory drilling.[210] The Forest Service’s no significant impact determination allowing it to avoid preparation of an EIS was arbitrary and capricious because it failed to adequately consider four of the “intensity” factors for determining environmental significance that the Council on Environmental Quality NEPA regulations say should be considered.[211]

The range of alternatives considered in the EA underlying the approval of this project was also deficient. First, the no action alternative of not permitting drilling was improperly rejected from full consideration because the Forest Service felt it was obligated to approve drilling.[212] But the court held that “none of the cited authorities [mandate] approval of proposed mineral extraction, forecloses a decision of No Action, or places the Forest Service’s objectives at odds with environmental preservation.”[213] Moreover, in considering BLM’s regulation at 43 C.F.R. § 3161.2, which directs the authorized officer to require that operations protect environmental quality and which will be discussed in more detail below,[214] the court held that “[t]he plain language of the regulation makes [it] clear that approval is not appropriate in all cases, particularly cases where the project poses a threat to environmental quality.”[215] Second, the court held that the range of alternatives considered was deficient “because it impermissibly limited the range of alternatives to only those that would meet [the project proponent’s] project objectives, rather than alternatives that might better serve Forest Service goals.”[216]

However, the court rejected a claim that the regulation at 43 C.F.R. § 3161.2, which again will be discussed in more detail below, was violated by the Forest Service’s approval of the project.[217] The basis for this holding was the court’s conclusion that violating NEPA did not demonstrate a violation of BLM’s substantive environmental protection regulation.[218] Compliance with BLM’s oil and gas operations regulations relating to environmental protection obligations was also considered in a case that originated in
New Mexico; this case will be considered infra in Part V.D.1.b.

Given this precedent, it is clear that when operations are proposed on a lease, BLM must interpret and implement its obligations in light of the policies established by NEPA, particularly if the lease was issued after 1969 when NEPA was enacted.[219] NEPA is an “applicable law” that a lease is “subject to.”[220]

But as explained above, the role of NEPA at the APD stage of oil and gas development has recently been reduced due to the availability of “categorical exclusions” from NEPA compliance that were created by the Energy Policy Act of 2005.[221] Twenty-eight percent of the APDs that
BLM approved between 2006 and 2008 were relieved of further NEPA compliance through the use of these categorical exclusions.[222] But categorical exclusions should not be viewed as completely eliminating application of NEPA in the oil and gas development process. These exclusions are available under five specified circumstances, and two of the conditions require that there has been prior NEPA compliance before an exclusion can be invoked.[223] And in the majority of field offices, any oil and gas development will occur pursuant to an RMP that was developed in compliance with NEPA.[224] Consequently, NEPA remains an “applicable law” that leases are made “subject to.”

3. The Federal Land Policy and Management Act

FLPMA, BLM’s organic act, establishes policy and requirements to protect the natural environment, including the policy that

the public lands be managed in a manner that will protect the quality of scientific, scenic, historical, ecological, environmental, air and atmospheric, water resource, and archeological values; that, where appropriate, will preserve and protect certain public lands in their natural condition; that will provide food and habitat for fish and wildlife and domestic animals; and that will provide for outdoor recreation and human occupancy and use.[225]

There is no doubt FLPMA is an applicable law that leases have been made subject to, at least if the lease was issued after 1976, which includes the majority of currently active leases in the eleven western states (see Table 1).

While FLPMA also establishes a policy that “recognizes the Nation’s need for domestic sources of minerals . . . including implementation of the Mining and Minerals Policy Act of 1970 as it pertains to the public lands,”[226] it seems clear the commodity development and environmental protection policies must be viewed as companion goals. Under FLPMA, BLM is required to manage the public lands under a multiple use and sustained yield mandate,[227] which requires, among other things, the

harmonious and coordinated management of the various resources without permanent impairment of the productivity of the land and the quality of the environment with consideration being given to the relative values of the resources and not necessarily to the combination of uses that will give the greatest economic return or the greatest unit output.[228]

And most importantly, FLPMA requires that “[i]n managing the public lands the Secretary [of the Interior] shall, by regulation or otherwise, take any action necessary to prevent unnecessary or undue degradation of the lands.”[229] There is little doubt that BLM views this provision as a specific, nondiscretionary statute.[230]

FLPMA’s mandate to prevent unnecessary or undue degradation imposes dual action requirements on BLM. It must take any action needed to prevent both unnecessary degradation as well as undue degradation of the public lands. This dual obligation was confirmed in Mineral Policy Center v. Norton.[231] Addressing this requirement, the court held that “Congress’s intent was clear: Interior is to prevent, not only unnecessary degradation, but also degradation that, while necessary to mining, is undue or excessive.”[232]
While the unnecessary degradation prong may only prevent activities that are not generally recognized or used to pursue mining operations, the undue degradation prohibition establishes a further requirement to prevent activities that would unduly harm or degrade the public land. As stated by the court, “FLPMA, by its plain terms, vests the Secretary of the Interior with the authority—and indeed the obligation—to disapprove of an otherwise permissible mining operation because the operation, though necessary for mining, would unduly harm or degrade the public land.”[233]

BLM has adopted regulations that define unnecessary or undue degradation (UUD) for purposes of hardrock mining pursuant to the General Mining Law,[234] but has no regulations that define UUD relative to oil and gas development. But one court agreed that “[a] reasonable interpretation of the word ‘unnecessary’ is that which is not necessary for mining. ‘Undue’ is that which is excessive, improper, immoderate or unwarranted.”[235] And IBLA determined that “Congress . . . recognized that the mere act of approving oil and gas development does not constitute unnecessary or undue degradation under [the] FLPMA, and that something more than the usual effects anticipated from such development, subject to appropriate mitigation, must occur for degradation to be ‘unnecessary or undue.’”[236] Despite these limited interpretations of the UUD clause, there is no doubt that this provision is specific and nondiscretionary and thus its requirements must be complied with when lease development is proposed.[237]

4. The Endangered Species Act

The Endangered Species Act of 1973 (ESA),[238] which of course seeks to protect threatened or endangered species listed under the Act, calls for special mention. BLM may recognize this law more than any other as being a “specific, nondiscretionary statute,” which thus guides (or limits) its management of oil and gas leases to a degree perhaps not reflected in its decision making for other resources.[239] The ESA was enacted in 1973, and thus, at a minimum, is applicable to the roughly 38,000 currently active leases in the eleven western states issued since 1973 (see Table 1). There is no doubt the ESA’s section 7 “jeopardy standard” and its section 9 prohibition on taking endangered species are specific and nondiscretionary provisions.[240] In addition, the Act requires the Secretary of the Interior to further the purposes of the ESA, including conserving the ecosystems upon which listed species depend and providing for their conservation.[241] Given these mandatory provisions, there is no doubt BLM has the authority, and in fact the obligation, to ensure compliance with the ESA when it makes development decisions related to federal oil and gas leases that could affect listed species.

The ESA establishes a number of requirements intended to foster the conservation of listed species, particularly regarding the prohibition under section 7 on federal actions that cause jeopardy to the continued existence of listed species.[242] Under these provisions, an agency can be required to prepare a biological assessment that considers the effects of an agency action on a listed species and engage in consultation with the United States Fish and Wildlife Service (FWS) regarding the effects of the action.[243] Consultation can result in an FWS biological opinion specifying mandatory terms and conditions for any incidental take of a listed species, recommended conservation measures intended to further protection and recovery of the species, and even a “jeopardy opinion,” which can effectively preclude the action.[244]

The courts have considered the requirements of the ESA in the context of the leasing decision in areas where listed species such as grizzly bears (Ursus arctos horribilis) and spectacled eiders (Somateria fischeri) exist.[245] Consultation with FWS must occur at the leasing stage, and the consultation must consider not only the effects of leasing on listed species, but also
“all phases of the agency action, which includes post-leasing activities.”[246]
In a challenge to the sale of sixteen lease parcels in an area of Colorado where the threatened hookless cactus (Sclerocactus glaucus) occurred, the court held BLM’s consultation with FWS was inadequate because the consultation failed to consider the full “action area” encompassed by all sixteen parcels, having considered only the nine parcels where the cactus occurred, and thus not recognizing potential indirect effects to the species.[247] But other courts have held that ESA challenges to leasing were not ripe for judicial resolution, and thus denied motions for summary judgment.[248] In Wyoming Outdoor Council v. Bosworth, however, the court recognized the ESA is a specific, nondiscretionary statute.[249]

5. Other Laws Applicable to Protection of the Public Lands

Besides these four overarching statutes, there are other laws that are at least applicable to federal oil and gas leases, and some are in all likelihood specific and nondiscretionary. In the interest of space I will not discuss these laws in detail but will note some of them:

  • Under section 106 of the National Historic Preservation Act of 1966,[250] BLM must take into account the effect of its undertakings on sites that are eligible for or included in the National Register of Historic Places.[251] And prior to approval of a federal undertaking that may affect a National Historic Landmark, the agency must minimize harm to the landmark “to the maximum extent possible.”[252]
  • The Archeological Resources Protection Act of 1979[253] provides that “[n]o person may excavate, remove, damage, or otherwise alter or deface . . . any archeological resource located on public lands . . . unless such activity is pursuant to a permit” and also prohibits attempting to do so.[254]
  • The Migratory Bird Treaty Act[255] has been in place since 1918 and makes it unlawful to take, kill, or otherwise possess or interfere with a number of migratory bird species subject to treaties between the United States and several countries unless done under the governing regulations of the Secretary of the Interior.[256] Similarly, the Bald and Golden Eagle Protection Act of 1940[257] makes it illegal to take or otherwise possess or interfere with bald eagles (Haliaeetus leucocephalus) and golden eagles (Aquila chrysaetos) unless done under permit.[258]
  • The National Trails System Act of 1968[259] established recreation, scenic, and historic trails.[260] Section 7(i) allows regulation of the use and protection of the trails,[261] and particularly with respect to historic trails such as the Oregon Trail, the provisions of the National Historic Preservation Act may also apply. Provisions of the National Wild and Scenic Rivers Act of 1968[262] might be applicable to some federal oil and gas leases.[263]
  • The Clean Air Act[264] declared a national purpose to protect and enhance air quality so as to promote the public health and welfare and a national goal of protection of visibility in highly scenic Class I areas, which include many wilderness areas and national parks.[265]
    It establishes a massive regulatory and permitting regime to ensure compliance with National Ambient Air Quality Standards for several “criteria” pollutants and provides for a number of other pollution control requirements.[266] These requirements are primarily implemented by the states, but the Clean Air Act also provides that all federal agencies having jurisdiction over a property or facility that may result in the discharge of air pollutants shall be subject to, and comply with, all requirements “respecting the control and abatement of air pollution in the same manner, and to the same extent as any nongovernmental entity.”[267]
  • The Clean Water Act[268] has as its objective attempting “to restore and maintain the chemical, physical, and biological integrity of the Nation’s waters,” and to achieve this objective it establishes goals that the discharge of water pollutants be eliminated, that fish and wildlife be protected, and that recreation be provided for in and on the water.[269] Like the Clean Air Act, a massive regulatory and permitting regime primarily administered by the states was created.[270] Under this regime several kinds of water quality standards or programs are created and enforced.[271] And using language that is the same as that found in the Clean Air Act, the Clean Water Act also makes its provisions for abatement of water pollution applicable to federal agencies “in the same manner, and to the same extent as any nongovernmental entity.”[272]
  • Several federal statutes respecting the management, control, cleanup, and reporting of chemicals and hazardous wastes or substances have been enacted. These include the Resource Conservation and Recovery Act of 1976 (RCRA);[273] the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (CERCLA),[274]
    also known as the Superfund; the Toxic Substances Control Act;[275] and the Emergency Planning and Community Right-To-Know Act of 1986.[276] Many of these statutes contain explicit exemptions for the oil and gas industry, and thus they may not be applicable laws relative to BLM oil and gas leases.[277] Nevertheless, chemicals and hazardous waste are subject to controls by BLM; some of the authorities establishing these rights will be discussed.[278] While these federal statutes may not be applicable laws in some cases, it is also apparent there are provisions dealing with hazardous wastes that are applicable.
  • Even noise pollution has come to the attention of Congress. Congress has found that inadequately controlled noise presents a danger to public health and welfare and has declared a policy “to promote an environment for all Americans free from noise that jeopardizes their health or welfare.”[279] And thus, “Congress authorizes and directs that Federal agencies shall, to the fullest extent consistent with their authority under Federal laws administered by them, carry out the programs within their control in such a manner as to further [this] policy.”[280]

It is apparent there is a wide range of environmental protection laws that are applicable to development of federally owned oil and gas resources, and a number of these are “specific, nondiscretionary statutes.”[281]

6. Energy Policy Statutes

In addition to the numerous environmental protection statutes that are “applicable” to federal oil and gas leases, provisions of federal energy policy are also applicable and evidence a goal of pursuing energy development on federal lands. Despite this goal, however, these laws have not repealed or amended the environmental protection statutes that have been discussed. Congress has declared a policy of support for energy development but also stated this would advance the goals of “protecting[] and enhancing environmental quality,” and assuring public health.[282] In the Mining and Minerals Policy Act of 1970,[283] Congress provided that it is the continuing policy of the federal government to “foster and encourage private enterprise” in the pursuit of minerals development.[284] Congress has sought to increase the recoverability of energy resources.[285] Section 604 of the Energy Policy and Conservation Act Amendments of 2000 (EPCA)[286] required an inventory of onshore federal lands to identify oil and gas resources underlying those lands, including an assessment of “the extent and nature of any restrictions or impediments to the development of the resources.”[287]

Probably most significantly, in the Energy Policy Act of 2005 Congress established several policies related to oil and gas development on the public lands. To ensure timely action on leases and APDs, the Secretary of the Interior is to “ensure expeditious compliance” with NEPA and take several other actions.[288] Best management practices (BMPs) are to be developed and implemented in order to improve the leasing program and ensure timely action on APDs.[289] Using these BMPs as guidance, regulations setting forth timeframes for processing leases and APDs are to be developed, and deadlines are to be established for approving or disapproving resource management plans, lease applications, APDs, surface use plans, and related administrative appeals.[290] And in section 390 of the Energy Policy Act of 2005, rebuttable presumptions allowing the use of categorical exclusions to meet NEPA obligations under five enumerated circumstances were established for oil and gas exploration or development activities.[291] Nevertheless, while Congress sought to speed up oil and gas development on the public lands through enactment of the Energy Policy Act of 2005, it did not require accomplishment of this goal by repealing the numerous applicable environmental protection laws that a lease might be subject to.

Based on this review of potentially “applicable laws” oil and gas leases have been made “subject to,” as well as a number of “specific, nondiscretionary statutes” that leases have also been made “subject to,” it is apparent BLM has many retained rights allowing it to protect the natural environment despite having granted a right to develop the oil and gas that might be found on a lease.[292] The federal government has retained significant rights allowing it to protect threatened or endangered species, prevent air and water pollution, control hazardous substances, regulate noise, ensure “care” is exercised in operations on a leasehold, regulate operations in order to conserve surface resources, protect historic trails and other cultural and archeological resources, prevent unnecessary or undue degradation of the public lands, and ensure the policies of NEPA are adhered to, among other things.[293] When coupled with the substantial rights retained under the “terms, conditions, and stipulations in the lease” and “regulations and formal orders” in effect when the lease was issued and even afterward if not inconsistent with the lease rights granted, it is apparent BLM has significant retained rights allowing it to specify to a significant degree the time, place, and manner of oil and gas development on a lease.[294] Retained rights stemming from lease terms, conditions, and stipulations will be considered next.

C. Terms, Conditions, and Attached Stipulations of BLM Oil and Gas Leases

As discussed in detail above, BLM’s leases, whether of the modern form or what is apparent in the examples of older leases, retain many rights to the federal government to protect the natural environment.[295] The terms and conditions in the leases provide that the rate of development and production can be specified; especially in the modern leases there are requirements to minimize adverse impacts to the environment, lease suspensions can be required, reclamation measures can be specified, and in some instances operations can be denied.[296] It is apparent that the contractual relationship established between BLM and its oil and gas lessees allows BLM to regulate the time, place, and manner of oil and gas development to a substantial degree under the terms and conditions of the lease.

But in addition to making the rights granted under a lease subject to the terms and conditions in the lease, the modern versions of the lease form operable since March 1984 state that the rights granted are subject to “attached stipulations of this lease.”[297] The § 3101.1-2 regulation in place since 1988 also makes leases “subject to” stipulations attached to the lease.[298] Stipulations have not been discussed previously.

BLM regulations provide that “[s]tipulations shall become part of the lease and shall supersede inconsistent provisions of the standard lease form.”[299] The lessee is deemed to agree to the terms of a stipulation.[300]
There are three types of stipulations BLM requires: 1) no surface occupancy (NSO) stipulations, 2) timing limitation stipulations (TLS), and 3) controlled surface use (CSU) stipulations.[301] NSO stipulations prohibit drilling on the surface of a lease or a described portion of it and are reserved for the most sensitive landscapes.[302] A TLS limits the time periods when drilling—but not operations and maintenance of production facilities—can occur, such as prohibiting drilling on big game crucial winter ranges between November 15th and April 30th.[303] A CSU stipulation prohibits surface occupancy unless certain operating constraints are met, such as limiting surface occupancy or use within 500 feet of riparian areas unless an acceptable mitigation plan is arrived at first.[304] There are many stipulations currently in use, protecting such things as historic trails and resources, threatened, endangered or special status species, high quality visual environments, raptors, and special management areas, among others.[305] In Wyoming, it is not unusual for a current lease to have between four to seven stipulations attached to it.[306] Examples of these stipulations can be seen in any BLM Notice of Competitive Oil and Gas Lease Sale.[307] BLM’s manual governing issuance of leases contains a number of provisions regarding stipulations.[308]

In addition to stipulations, current leases also often have “information notices” attached to them.[309] There are currently three lease notices in use in Wyoming: one applicable to protections for steep slopes and certain other resources, one applicable to historic trails, and one applicable to the greater sage-grouse.[310] While these notices express an intent to protect these resources, they probably have little or no legal consequence:

An information notice has no legal consequences, except to give notice of existing requirements, and . . . [only] convey[s] certain operational, procedural or administrative requirements relative to lease management within the terms and conditions of the standard lease form. Information notices shall not be a basis for denial of lease operations.[311]

“The issuance of the Information Notices therefore establishe[s] no binding policy or practice . . . .”[312] So while these notices certainly express a goal of BLM’s to protect resources like the sage-grouse, the legal authority for any resulting actions must be found in the lease itself, in the § 3101.1-2 regulation, or in other law, not in the lease notice.

D. Regulations and Formal Orders

With respect to modern versions of the lease form issued since 1984, the rights granted under the lease are made subject to two conditions related to compliance with regulations and formal orders, one applicable to regulations and formal orders in place when the lease is issued, and the other to later-adopted regulations and formal orders. In the modern lease forms, the rights granted are subject to “the Secretary of the Interior’s regulations and formal orders in effect as of lease issuance” and are additionally subject to “regulations and formal orders hereafter promulgated when not inconsistent with lease rights granted or specific provisions of this lease.”[313] The older versions of the lease from 1954, 1965, and 1971 provide that the offer to lease is pursuant and subject to the rules and regulations of the Secretary of the Interior “now or hereafter in effect” when not inconsistent with the lease rights granted.[314] These conditions on the exercise of lease rights will be considered next.

1. Regulations

a. The Regulations at 43 C.F.R. Part 3100

BLM’s current leasing regulations are found at 43 C.F.R. part 3100.
The § 3101.1-2 regulation that elaborates on the rights granted to the lessee and BLM’s retained rights when an oil and gas lease is issued was discussed in some detail above,[315] as was the § 3101.1-1 regulation that provides that leases shall be issued only on standard forms.[316] In addition, the regulations applicable to stipulations were just discussed.[317] An additional regulation in this part provides that “[a] suspension of all operations and production may be directed or consented to by the authorized officer only in the interest of conservation of natural resources.”[318] Suspension of lease operations is a significant means by which BLM can exercise its retained rights to protect the natural environment.[319] When a suspension occurs, the term of the lease is extended by the period of time of the suspension, and rental and minimum royalty payments are also suspended.[320] Few other regulations in part 3100 likely implicate BLM’s retained rights with respect to environmental protection after issuing an oil and gas lease.[321]

The current version of BLM’s oil and gas leasing regulations was promulgated in 1988.[322] Thus, the current version of the part 3100 regulations would clearly apply to the 34,367 currently active leases in the eleven western states issued since that date (see Table 1). Most significantly, the § 3101.1-2 regulation applies to these leases, which represent seventy-one percent of the currently active leases in the eleven western states (see Table 1).

Prior to adoption of the 1988 version of the leasing regulations, which were promulgated to comply with FOOGLRA,[323] several iterations of the leasing regulations had been in place. Regulations governing oil and gas leases were in place in 1938, and notices of modifications to the regulations were published in the Federal Register in 1946, 1954, 1964, 1970, and 1983.[324] The 1983 regulations contained a provision in § 3101.1-2, but it was amended when the 1988 version that has been discussed extensively was adopted.
The 1983 version provided that stipulations could be attached to a lease only if either “the stipulations did not absolutely bar exploration” or the lease as stipulated remained acceptable to the offeror.[325] With respect to provisions allowing BLM to ensure protection of the environment, many of the older versions of the leasing regulations provided for suspensions and stipulations.[326]

Whether leases issued prior to 1988 are subject to the current leasing regulations, particularly the § 3101.1-2 regulation, is debatable, but the broad reservations contained in the 1954, 1965, and 1971 leases, such as the term allowing the rate of prospecting and development and the quantity and rate of production to be subject to BLM control in the public interest, [327] suggest that these leases could be subject to the later-adopted regulations. The older leases provide that reasonable regulations “hereafter in force” apply to the lease if not inconsistent with the provisions in the lease.[328] Section 6 of the 1984 version of the lease form already allowed for reasonable measures to be required, even before the § 3101.1-2 regulation was promulgated in 1988.[329] Accordingly, the current version of the leasing regulations could well apply to leases issued prior to 1988. However, as will be discussed below, in some circumstances the courts have not been receptive to allowing later-enacted statutes to govern a lease.[330]

b. The Regulations at 43 C.F.R. Part 3160 and Other BLM Regulations

In addition to its leasing regulations, BLM also has an extensive body of regulations governing onshore lease operations. These regulations are found at 43 C.F.R. part 3160.[331] BLM’s current operating regulations are replete with provisions allowing BLM to protect the natural environment when operations are proposed, including the following:

  • “The authorized officer is authorized and directed to . . . require compliance with lease terms, with the regulations in this title and all other applicable regulations promulgated under the cited laws; and to require that all operations be conducted in a manner which protects other natural resources and the environmental quality . . . .”[332]
  • “Before approving operations on [a] leasehold, the authorized officer shall determine . . . that the proposed plan of operations is sound both from a technical and environmental standpoint.”[333]
  • Operators are to comply with applicable laws, regulations, lease terms, onshore oil and gas orders, notices to lessees, and other orders and instructions from BLM, including but not limited to conducting all operations in a manner that “protects other natural resources and environmental quality.”[334]
  • The regulations make extensive provisions regarding submission of APDs, including requiring submission of a surface use plan of operations which must contain information regarding roads and drill pads, methods for containment and disposal of waste materials, and reclamation plans.[335]
  • “The operator shall conduct operations in a manner which protects the mineral resources, other natural resources, and environmental quality,” which obligates the operator to comply with all pertinent orders, applicable laws, regulations, lease terms and conditions, and the approved drilling plan.[336] BLM is to prepare an environmental review to ensure compliance with NEPA, and this environmental review can be used to determine terms and conditions of approval of the proposed drilling plan.[337]
  • “The operator shall exercise due care and diligence to assure that leasehold operations do not result in undue damage to surface or subsurface resources or surface improvements.”[338]
  • Operators may be subject to penalties for noncompliance with these regulations, including shut down or shut-in of operations where significant environmental impacts are occurring.[339]

While these regulations clearly create mandatory obligations to protect the environment, that is not their sole purpose. The regulations at 43 C.F.R. §§ 3161.2 and 3162.1(a) require actions to protect the environment, but they also specifically provide that an objective of operations is to maximize oil and gas recovery.[340]

Moreover, one court, in Blancett v. U.S. Bureau of Land Management,[341] determined many of these regulations do not provide a basis for a “failure to act” claim pursuant to the Administrative Procedure Act.[342] This case concerned claims that BLM had failed to protect the environment from oil and gas operations that affected a ranch in New Mexico.[343] The court ruled that while the regulations at 43 C.F.R. §§ 3161.2, 3162.1(a), and 3162.5-1(a)–(b) established broad objectives, “none of the regulations in Part 3160 imposes a mandatory duty on BLM to protect the environment with the specificity required to support a claim under § 706(1) of the [Administrative Procedure Act].”[344] It found the regulations did not specify discrete agency action and did not define actions that were legally required.[345] Thus, the plaintiffs’ lawsuit failed the two-part test under the Supreme Court’s precedent in Norton v. Southern Utah Wilderness Alliance[346] that is required to support a § 706(1) claim.[347] Consequently, the court granted BLM’s motion to dismiss the lawsuit based on the pleadings and found that it did not have subject matter jurisdiction. However, because the dismissal without prejudice did not constitute a decision on the merits,[348] the precedential value of this unpublished decision is limited. BLM’s obligations to protect the environment will be considered further in Part IX.[349]

Despite the decision in Blancett, it seems clear that even if BLM’s operations regulations do not mandate particular actions by BLM that can be enforced in court, the regulations nevertheless provide that BLM is obligated to require environmental protection when it permits oil and gas development. As the court recognized in Blancett, defendant BLM “acknowledge[s] that the regulations charge BLM with requiring operator compliance with lease terms and regulations and with requiring that operations be conducted in a manner that protects environmental quality.”[350]

A form of the part 3160 regulations that closely approximates the current version of the regulations with respect to environmental protection obligations has been in place since 1982 when the Minerals Management Service (MMS) amended the predecessor regulations.[351] The 1982 regulations were intended to be codified at 30 C.F.R. part 221, and at that time onshore operations were under the direction of MMS, not BLM.[352] However, the 1982 regulations were amended again in August 1983. In the 1983 revision the regulations were transferred from 30 C.F.R. part 221 and redesignated as
43 C.F.R. part 3160, and the management authority was transferred to BLM.[353] In 1988, as part of the regulatory revisions needed to conform to FOOGLRA, the operating regulation governing APDs was modified to its current form by adding requirements related to surface use plans of operation, as well as other provisions.[354] Thus, with respect to environmental protection provisions, the current version of the operations regulations has been fully in place since 1988,[355] but regulations quite similar to, and often identical to, the current regulations have been in place since 1982.[356] Consequently, the vast majority of currently active leases in the eleven western states are subject to the current operating regulations or a version very similar to them (see Table 1).

Prior to the 1982 revision of the regulations, MMS managed oil and gas operations under regulations adopted in 1942.[357] The 1942 regulations, which were in place for forty years,[358] provided for less in the way of environmental protection than the current regulations, but they did provide that “[t]he lessee shall not pollute streams or damage the surface or pollute the underground water of the leased or other land.”[359] More generally, the old operations regulations required compliance with lease terms, regulations, and applicable law.[360]

In addition to the part 3160 regulations, BLM also promulgated regulations governing approval of land use authorizations. With respect to provisions that are relevant here, these regulations have been in place since 1981.[361] These regulations provide that the United States reserves the right to use the public lands or authorize the use of the public lands by the general public in ways that are compatible or consistent with the land-use authorization.[362] They also provide that each land-use authorization shall contain terms and conditions that shall minimize damage to scenic, cultural, and aesthetic values and wildlife habitat and that “otherwise protect the environment”;[363] require compliance with air and water quality standards;[364] and require compliance with state environmental protection standards that are more stringent than federal standards.[365] Land-use authorizations shall also contain provisions that “[r]equire the use to be located in an area which shall cause least damage to the environment, taking into consideration feasibility”[366] and to “[o]therwise protect the public interest.”[367] Other provisions provide for inspection and monitoring during construction, operation, and maintenance of the land-use authorization so as to protect
the environment.[368]

In sum, BLM’s oil and gas leasing regulations, its oil and gas operations regulations, and the land-use authorization regulations provide an additional and substantial basis for BLM to assert retained rights so as to protect the natural environment. The leasing regulations have existed in their present form since 1988, the operations regulations have been in essentially their current form since 1982, and the relevant land-use authorization regulations have been in place since 1981. Consequently the majority of currently active leases in the eleven western states are subject to these provisions without need to consider the question of whether later-adopted regulations were incorporated into a lease or were consistent with lease rights previously granted (see Table 1).

2. Formal Orders

Beyond these regulatory provisions are a number of authorities that could be “formal orders,” which many leases are also subject to—particularly leases issued since 1984 when this condition on the granted lease rights was introduced.[369] These formal orders could include BLM Resource Management Plans (RMPs) developed pursuant to FLPMA, onshore oil and gas orders, notices to lessees, provisions in the BLM manual and handbook, BLM instruction memoranda, BLM’s “Gold Book,”
Executive Orders, and Department of the Interior Solicitor opinions and Secretarial orders. These sources of authority will be considered next.

a. Resource Management Plans

BLM RMPs are required by FLPMA,[370] and their role in the oil and gas leasing and development process was discussed above.[371] Once an RMP is developed, the Secretary of the Interior shall manage the public lands governed by the plan in accordance with the plan.[372] There seems to be little doubt that an RMP constitutes a formal order that an oil and gas lease issued since 1984 is subject to.

The first RMPs were adopted in the early to mid-1980s.[373] Accordingly, oil and gas leases have been made subject to these formal orders since approximately the mid-1980s. As indicated several times above, it seems likely that older leases are also subject to the provisions in a later-adopted RMP because the expansive language in older leases—“not inconsistent with any express and specific provisions herein”[374]—arguably makes the older leases subject to the later-adopted RMP provisions. For RMPs adopted after 1984, the RMP provisions could well be “not inconsistent with lease rights granted or specific provisions of this lease,” as provided for in the modern lease form in place since 1984.[375]

RMPs provide general guidance for oil and gas development that might occur pursuant to them.[376] Under the BLM handbook governing land-use planning, an RMP should identify areas open to leasing subject to various constraint levels—for example, an area may be open to leasing with “moderate constraints” such as seasonal and controlled surface-use restrictions; identify areas closed to leasing; identify lease stipulations, conditions of approval, and best management practices that will be employed; identify “[w]hether constraints identified in the land use plan for new leases also apply to areas currently under lease”; and define “resource condition objectives for areas under development to guide reclamation activities in these areas.”[377] Thus, RMPs contain considerable guidance that oil and gas leases are subjec to.

b. Onshore Oil and Gas Orders

BLM is authorized to issue Onshore Oil and Gas Orders when necessary to implement or supplement the oil and gas operations regulations.[378]
Seven onshore orders are currently in effect.[379] They deal with drilling and disposal of produced water, site security, and other issues. An onshore order is “binding on operating rights owners and operators.”[380]

The most significant onshore order for purposes of this discussion is Onshore Oil and Gas Order Number 1.[381] This order was first adopted on October 21, 1983,[382] and it was most recently revised on March 7, 2007.[383]
It governs approval of oil and gas exploratory, development, and service wells and most subsequent well operations on essentially all federal onshore oil and gas leases.[384] The order governs APDs including their accompanying drilling plans and surface use plan of operations.[385] Among other things, the order describes a number of requirements for the surface-use plan of operations.[386] These include provisions for revegetation of disturbed areas and the safe containment and disposal of waste material (including chemicals).[387] The processing of APDs is discussed and prescribed in detail, including requirements for on-site inspections.[388] BLM can approve, defer, or deny an APD depending on whether certain requirements have been met; this includes a provision that “BLM cannot approve an APD or Master Development Plan until the requirements of certain other laws and regulations including NEPA, the National Historic Preservation Act, and the Endangered Species Act have been met.”[389] Onshore Order Number 1 then makes this provision:

The approved APD will contain Conditions of Approval that reflect necessary mitigation measures. In accordance with 43 CFR 3101.1-2 . . . , the BLM . . . may require reasonable mitigation measures to ensure that the proposed operations minimize adverse impacts to other resources, uses, and users, consistent with granted lease rights. The BLM will incorporate any mitigation requirements, including Best Management Practices, identified through the APD review and appropriate NEPA and related analyses, as Conditions of Approval to the APD.[390]

It is noteworthy that the “reasonable mitigation measures” referred to here are not confined to the “200-meter 60-day rule” limitations mentioned in the § 3101.1-2 regulation, and thus these reasonable mitigation measures are arguably not limited accordingly; this is consistent with both the language in the § 3101.1-2 regulation and section 6 of the standard lease form in use since 1984.[391] Moreover, there is no indication in Onshore Order Number 1 that the heightened clear and convincing evidence standard presented in IM 92-67 and BLM Manual MS-3101 is applicable for determining reasonable measures.[392]

Onshore Order Number 1 also specifies several general operating requirements. It provides that “[t]he operator must conduct operations to minimize adverse effects to surface and subsurface resources, prevent unnecessary surface disturbance, and conform with currently available technology and practice.”[393] Furthermore, “[t]he operator must comply with the provisions of the approved APD and applicable laws, regulations, Orders, and Notices to Lessees, including but not limited to [several specified provisions, including provisions related to cultural and historic resources, ESA compliance, and surface protection].”[394]

While the current version of Onshore Order Number 1 has only been in place since March 2007, as noted, it has been in place in some form since October 1983.[395] Thus, the roughly 36,000 leases issued since 1983 are subject to this formal order in one of its previous versions (see Table 1). As claimed elsewhere, it is not clear that the newest version of Onshore Order Number 1 would necessarily be inconsistent with lease rights granted in older leases since those older leases contain at least somewhat expansive reservations of authority allowing actions to be taken to protect the environment and other resources.[396]

c. Notices to Lessees

Another kind of formal order that is recognized is the notice to lessee (NTL). The BLM authorized officer may issue an NTL “when necessary to implement the onshore oil and gas orders and the regulations in this part.”[397] NTLs “implement the regulations in [part 3160] and operating orders, and serve as instructions on specific item(s) of importance within a State, District, or Area.”[398]

There are three operable NTLs in Wyoming, which are posted on BLM’s website.[399] One of these addresses flow meters,[400] another deals with reporting “undesirable events,”[401] and the last deals with royalties from lost oil and gas.[402] The flow meter NTL is applicable in Wyoming and the other two NTLs apply nationwide.[403] According to BLM personnel, there is a trend to convert NTLs to onshore oil and gas orders and many are only applicable in a particular state.[404]

d. The BLM Manual and Handbook

BLM also has an agency manual and handbook.[405] The BLM manual “provides policy, procedures, and instructions to manage programs.”[406]
The BLM handbook is a “source of detailed instructions for performing specialized procedures to carry out policy and direction described in the Manual Section.”[407] According to the BLM handbook, “[H]andbooks are considered part of the Manual.”[408] It is debatable whether the provisions in the manual and handbook constitute formal orders since they are not developed pursuant to the formal notice-and-comment rulemaking procedures specified by the Administrative Procedure Act,[409] however there is no doubt these internal sources of guidance play a major role in BLM’s day-to-day decision making.[410]

Potentially relevant manual sections that could constitute formal orders that a lease has been made subject to include but are not limited to the following: MS-1601 (land-use planning); MS-1703 (hazardous materials management and resource restoration); MS-3150 (onshore oil and gas geophysical exploration surface management requirements); MS-6840 (special status species management); and MS-8110, -8130, -8140, and -8150 (relating to various aspects of cultural resources management).[411] Potentially relevant handbook sections include but are not limited to H-1601-1 (land-use planning), H-1740-2 (integrated vegetation management), H-1790-1 (NEPA), H-3070-2 (economic evaluation of oil and gas properties), H-3101-1 (issuance of leases), H-3110-1 (noncompetitive leases), H-3150-1 (onshore oil and gas geophysical exploration surface management requirements), and H-3203-1 (leasing terms).[412]

In the interest of space, I will make no effort to review all of the provisions in this guidance. This would be a daunting task, and it might well be virtually impossible to determine what versions of these documents were in place at various times in the past. However, there are potentially a number of relevant provisions that could constitute formal orders, perhaps most significantly those found in the handbook section entitled “Planning for Fluid Minerals Resources.”[413] The provisions in BLM Manual MS-3101, relating to issuance of leases, are also relevant and some have been discussed.[414]

e. BLM Instruction Memoranda

In addition to manual and handbook provisions, BLM also has an extensive library of “Instruction Memoranda” (IMs), which may also be formal orders that a lease is subject to, at least if the lease was issued since 1984 when the “formal orders” language was adopted in the standard lease form. IMs “are temporary directives that supplement the Bureau Manual Sections.”[415] The BLM website presents IMs that have been issued since 1999.[416] Generally they are directives from the BLM Director to BLM state directors and field office officials, although state offices may also issue IMs.[417] Most, if not all, IMs have associated expiration dates,[418] so it is debatable whether they have continuing force after they expire, even if the IM was in force when a lease was issued. But BLM sometimes continues to treat IMs as effective after they have nominally expired.[419] At this time,
IMs 2009-225, 2009-078, 2009-044, and 2009-011 are operational at a minimum (all expire on September 30, 2010).[420] These IMs address a range of topics including oil and gas inspection and enforcement strategies,[421] processing APDs that employ directional drilling from well pads on nonfederal lands,[422] the use of categorical exclusions from NEPA compliance for geophysical exploration,[423] and assessment and mitigation of impacts to paleontological resources.[424] Many other nominally expired IMs relate to oil and gas development.[425]

f. The BLM “Gold Book”

An additional BLM document that could constitute a formal order is The Gold Book (actually entitled Surface Operating Standards and Guidelines for Oil and Gas Exploration and Development: The Gold Book).[426] While this document also has not been adopted through formal notice-and-comment rulemaking, it is an important source of information and guidance for BLM decision making regarding operations on an oil and gas lease.[427] It is essentially a user-friendly companion to Onshore Oil and Gas Order Number 1.

The Gold Book provides a wide array of guidance (and requirements) relative to all phases of oil and gas development operations. It was “developed to assist operators by providing information on the requirements for obtaining permit approval and conducting environmentally responsible oil and gas operations on Federal lands.”[428] It defines “Best Management Practices” as measures that “minimiz[e] undesirable impacts to the environment” and promotes the use of best management practices to achieve this end.[429] The Gold Book states that “[c]onstraints . . . may be imposed on the location of access roads, well sites, and facility sites or the timing of geophysical exploration, well drilling, or other operations” and “may result from lease stipulations, the surface management agency’s review and environmental analysis of the proposed operations, Notices to Lessees, Onshore Orders, or regulations.”[430] The Gold Book specifies that environmental concerns might be addressed through conditions of approval or best management practices that result from a site-specific analysis.[431] Thus, design and construction techniques for well sites should “minimize surface disturbance and the associated effects of proposed operations and maintain the reclamation potential of the site.”[432] There are a number of specific considerations related to construction of well sites, reserve pits, roads and access ways, and drainage and drainage structures.[433] Guidance for drilling and production operations is also specified, as “[o]nshore oil and gas lease operations are subject to applicable laws, regulations, lease terms, the [APD], APD conditions of approval, Onshore Oil and Gas Orders, Notices to Lessees, and orders and instructions of the authorized officer.”[434]
These obligations aim to ensure that the conduct of operations protects “natural resources, environmental quality, life, and property.”[435] Maximizing oil and gas recovery with minimum adverse effect on the environment is “[t]he primary objective.”[436] To achieve these objectives, The Gold Book details measures for disposal of produced water, pollution control and hazardous waste management, noise control, protection of visual and scenic resources, and even how facilities should be painted.[437] The Gold Book also specifies reclamation measures.[438]

g. Presidential Executive Orders

Executive Orders (EOs) issued by the President of the United States are official documents by which the President manages the operations of the executive branch. A number of these relate to obligations of the federal government to protect the natural environment. There is no doubt they are formal orders that many leases are subject to.

A few of the active EOs indicate the extent to which BLM retains rights in areas that have been leased for oil and gas development. President Carter issued EOs 11,990 and 11,988 in 1977 to guide and establish requirements for federal protection of floodplains and wetlands.[439] EO 12,088, issued by President Carter in 1978, provides that “[t]he head of each Executive agency is responsible for ensuring that all necessary actions are taken for the prevention, control, and abatement of environmental pollution with respect to Federal facilities and activities under the control of the agency.”[440] President Nixon issued EO 11,593 in 1971 to guide and establish obligations for the protection of cultural and historical resources.[441] EO 13,186, issued by President Clinton in 2001, provides for the conservation of migratory birds.[442]

In addition to EOs aimed at protecting the natural environment, there are EOs that address energy development. President George W. Bush issued EO 13,211 in 2001 to require the preparation of a Statement of Energy Effects for federal regulatory actions that can have significant adverse effects on the supply, distribution, or use of energy.[443] EO 13,212, also issued by President Bush in 2001, requires federal agencies to expedite permitting of energy projects.[444] It states, “For energy-related projects, agencies shall expedite their review of permits or take other actions as necessary to accelerate the completion of such projects, while maintaining safety, public health, and environmental protections.”[445] These directives to further energy production have not eliminated requirements to protect the natural environment when federal oil and gas leases are developed.

h. Solicitor Opinions and Secretarial Orders

Finally, two additional types of formal orders that a lease may be subject to are opinions of the Solicitor of the U.S. Department of the Interior and orders issued by the Secretary of the Interior. A list of, and access to, many of these opinions and orders can be found online.[446] On January 6, 2010, Secretary of the Interior Ken Salazar issued Secretarial Order 3294, which established an Energy Reform Team in the Department of the Interior that will oversee evaluation and reform of Department energy policies.[447] Part and parcel of this reform effort was the establishment of new policies regarding onshore oil and gas leasing under the management of BLM. This includes a requirement for “Master Leasing and Development Plans” prior to leasing in areas where intensive new oil and gas development is anticipated, and increased environmental review of lease parcels leading to identification of mitigation measures.[448] This new policy direction could lead to substantial changes in BLM’s oil and gas program and to issues related to BLM’s assertion of its retained rights. This new direction will be discussed further in Part VIII.B.

E. Reasonable Measures

“Reasonable measures” is the last of the several conditions that a BLM oil and gas lease is subject to. This option for ensuring environmental protection when operations are proposed on a lease, which is provided for by both the § 3101.1-2 regulation and section 6 of the modern lease form, has been discussed in some detail above.[449] BLM can require reasonable measures to minimize adverse effects to the environment that include, but are not limited to, modifying the siting and design of facilities, timing of operations, and specifying interim and final reclamation measures, so long as the reasonable measures are consistent with the lease rights granted.[450]

As is apparent from this lengthy discussion of legal authorities,
BLM has substantial retained rights under the lease contract that allow it to protect the natural environment when lease development is proposed.
But furthermore, in addition to what is apparent from this analysis, basic principles of contract law may also help define or illuminate BLM’s retained rights. These principles will be considered next.

VI. General Principles of Contract Law Will Help Define BLM’s
Retained Rights

  1. Court Decisions Related to Federal Oil and Gas Leases Have Relied on General Principles of Contract Law

Courts evaluating the federal government’s rights and duties under federal oil and gas leases have considered basic principles of contract law. Consequently, it is appropriate to not only consider the provisions and legal authorities lease contracts are specifically subject to when determining BLM’s retained rights in leased land, but to also consider more general contract law principles. There is, of course, a large body of law that has been developed around contracts.

In Mobil Oil Exploration and Producing Southeast, Inc. v. United States (Mobil Oil),[451] the United States Supreme Court considered oil and gas leases off the North Carolina coast that were issued pursuant to the Outer Continental Shelf Leasing Act (OCSLA) and held that repudiation of the leases occurred when the federal government refused to take a required action (approval of an exploration plan) within a specified timeline.[452]
The Court noted, “[W]hen the United States enters into contract relations, its rights and duties therein are governed generally by the law applicable to contracts between private individuals.”[453] Based on this, the Court looked to the Restatement (Second) of Contracts for a definition of when repudiation and breach of contract occurs, and also stated that “[t]he Restatement of Contracts reflects many of the principles of contract law that are applicable to this action.”[454] Mobil Oil will be considered further in Part VII.B.

Similarly, in another offshore leasing case that dealt with OCSLA leases off the California coast, Amber Resources Co. v. United States,[455] the United States Court of Appeals for the Federal Circuit ruled that the government had breached the lease contracts when it altered the terms of suspensions.[456] Again, the court looked to the Restatement (Second) of Contracts for guidance on when repudiation and breach occurs. The court relied on the Supreme Court’s analysis in Mobil Oil to reach its conclusion.[457]

In considering state law claims related to assignments of leases and royalty interests based on BLM onshore oil and gas leases, the District Court in Wyoming determined that reservation language should be examined
“in accordance with the general principles of contract interpretation.”[458] Relying on Wyoming Supreme Court precedent, the court determined the prime focus should be on the intent of the parties and where the language of a contract is unambiguous, intent should be gathered from the contract itself, although the context within which the document was written can be considered.[459] If contract language is ambiguous, extrinsic evidence can
be considered.[460]

Another case originating in Wyoming stemmed from BLM decisions to suspend oil and gas leases in an area with rich trona deposits so that trona mining could occur prior to oil and gas development.[461] The United States Court of Federal Claims observed that when determining whether the suit was timely filed, repudiation of a contract occurs when the government announces it will not perform contractual obligations and a breach of contract occurs when the government actually fails to honor its obligations or when the promisee brings suit in the face of a repudiation.[462]

Given this precedent it is appropriate to consider underlying principles of contract law that might help define the scope and nature of obligations under a federal onshore oil and gas lease, and thus BLM’s retained rights and duties pursuant to a lease. This will be done next by briefly considering some of the relevant guidance in the Restatement (Second) of Contracts and American Jurisprudence 2d Contracts.

B. Contract Principles Presented in the Restatement of Contracts and American Jurisprudence

The initial question in construction of a contract is a determination of whether the contract is ambiguous.[463] Contract language is unambiguous when it has a “definite and precise meaning,” and if the contract is unambiguous “the rules governing the interpretation of ambiguous contracts do not come into play.”[464] The meaning of an unambiguous contract is determined without reference to extrinsic facts or aids and “it must be enforced as written.”[465] Ambiguity is determined objectively through the eyes of a reasonably intelligent person, considering the entire written agreement.[466] Ambiguity is not created just because a contract will work hardship on one party, or the parties disagree over the meaning of a contract, or urge varying interpretations.[467] Ambiguity must emanate from the language used in the contract, “rather than from one party’s subjective perception of its terms.”[468]

Where there is ambiguity, the intention of the parties to the contract will be sought; “the fundamental and cardinal rule in the construction or interpretation of contracts is that the intention of the parties is to be ascertained.”[469] If the contract is not ambiguous, intent is determined from the language used in the contract.[470] The intention or meaning of a contract can be conveyed by implication if such is plainly required by the language in the contract.[471]

Other principles of contract law can also affect construction and interpretation. Ambiguous language is interpreted most strongly against the drafting party, which is certainly BLM when it comes to onshore oil and gas leases.[472] However, in contracts where the government enters into the contract on behalf of the public, the contract is liberally construed in favor of the government.[473] There is an implied covenant of good faith and fair dealing in every contract, but this duty does not alter a contract’s express provisions.[474] Parties to a contract are presumed to contract with reference to existing law.[475] Existing law is made part of the contract, but subsequent law is not made part of a contract unless there is clear expression in the contract to do so.[476]

A federal onshore oil and gas lease is, undoubtedly, a written, integrated agreement between the government and the lessee.[477] Thus, the language used in the lease will likely determine which rights to condition development are retained by BLM, an issue which has been discussed at length elsewhere. The language in a federal onshore oil and gas lease is arguably unambiguous, so interpretation of what rights BLM retains will likely be based on consideration of that language and not extrinsic evidence. But that of course could be subject to debate; a claim might be made in a particular circumstance that ambiguity exists and extrinsic evidence needs to be considered to interpret the contract.

The intent of the parties to a BLM oil and gas lease is to allow for, and even promote, oil and gas development on public lands.[478] Modern versions of the lease form state, “This lease is issued granting the exclusive right to drill for, mine, extract, remove and dispose of all the oil and gas (except helium) in the lands described . . . together with the right to build and maintain necessary improvements thereupon.”[479] The three older versions of the lease form make a nearly equivalent grant.[480] Yet, in the next sentence following this grant, modern versions of the lease state “[r]ights granted are subject to” the authorities discussed above at length—applicable laws;
lease terms, conditions, and stipulations; regulations and formal orders in place when the lease is issued; and regulations and formal orders issued afterward if not inconsistent with the lease rights granted.[481] The § 3101.1-2 regulation adds to this list.[482] And while older versions of the lease form may be less explicit, they nevertheless provide that “lessee agrees” to take reasonable steps to prevent certain specified types of environmental damage, “lessor reserves” certain rights, and that “it is agreed” that the rate of prospecting and development and the quantity and rate of production are subject to control in the public interest by the Secretary of the Interior.[483]

Parties to an onshore federal oil and gas lease intend to allow for oil and gas resource development; however, they also understand that, or should understand that, any such development is conditional.[484] Consequently, when general principles of contract law are considered, it is apparent that BLM has significant retained rights under a lease allowing it to condition development to protect the natural environment. The provision in section 6 of the modern version of the standard lease form, stating that BLM can specify reasonable measures to minimize adverse impacts to resources, is perhaps the provision that is most likely to be challenged as ambiguous. However, the language that appears in section 6 of the October 2008 standard lease form states that the “[l]essee must take reasonable measures deemed necessary by lessor to accomplish the intent of this section.”[485]
The intent specified is to “conduct operations in a manner that minimizes adverse impacts” to various resources, and it is stated that reasonable measures “include, but are not limited to, modification to siting or design of facilities, timing of operations, and specification of interim and final reclamation measures” so long as consistent with the lease rights granted.[486] Therefore, it would appear that reasonable measures could include any measures that BLM might require so long as they did not take away the exclusive right to remove all of the oil and gas on a leasehold or prohibit the construction of necessary improvements. Any condition short of this appears to be within BLM’s discretion and within the meaning of the term reasonable measures as used in the standard lease form. In Yates Petroleum Corp.,[487] the Interior Board of Land Appeals (IBLA) rejected an attempt to limit BLM’s imposition of reasonable measures to nothing more stringent than those mentioned in the 200-meter 60-day rule and recognized BLM could restrict the siting or timing of lease activities.[488] Thus, a highly constrained interpretation of what constitutes reasonable measures likely will not succeed, especially in light of the general contract principle that when the government enters into a contract on behalf of the public, then the contract is construed in favor of the public.[489]

VII. Potential Limitations on BLM’s Ability to Exercise Its
Retained Rights

I have discussed in detail the authorities that support BLM’s assertion of considerable retained rights in areas it has leased for oil and gas development, allowing it to protect the natural environment through the exercise or implementation of those retained rights. But of course, this is not a one-way street, and consideration must be given to contrary authority that could limit the exercise of any asserted retained rights. Some of these possible contrary authorities will be considered in this section.

A. The Lessee Has Been Granted the Right to Use as Much of the Leased Lands as Is Necessary to Remove All of the Oil and Gas and the Right to Build Necessary Improvements

Modern versions of the lease form in use since 1984 grant the exclusive right to remove all of the oil and gas on a leasehold and the right to build and maintain necessary improvements thereupon.[490] The § 3101.1-2 regulation supplements this grant by providing that “[a] lessee shall have the right to use so much of the leased lands as is necessary to [remove] all the leased resource in a leasehold.”[491] As discussed, under the modern lease forms and the § 3101.1-2 regulation three rights have been granted: 1) the exclusive right to use the leasehold for the removal of all oil and gas; 2) the right to “use” as much of the leasehold as is “necessary” to remove “all” of the oil and gas; and 3) a right to build “necessary” improvements.[492] The three older versions of the lease grant similar rights, but these lease forms were in use prior to promulgation of the § 3101.1-2 regulation in 1988. The 1954, 1965, and 1971 versions of the lease form all provide that the lessee is granted the “exclusive right and privilege to [remove] all the oil and gas . . . in the lands leased, together with the right to construct and maintain [structures] necessary to the full enjoyment thereof.”[493]

In considering whether these granted rights might limit BLM’s ability to assert retained rights to limit or guide development, it seems unlikely there will often be dispute that a particular lessee has the exclusive right to access the oil and gas on a leasehold. Thus, the more critical questions likely relate to what actions might be “necessary” for the use of the leasehold for the removal of all the oil and gas, and what might constitute “necessary” improvements.

The right to do what is necessary to access all of the oil and gas that may be found on a lease and the right to build and maintain necessary improvements should not be viewed as granting an unfettered right to do anything the lessee may desire to extract the oil and gas. The word “necessary” gathers meaning from the connection in which it is used.[494] It can mean absolute physical necessity or inevitability, or it can mean only that which is “convenient, useful, appropriate, suitable, proper, or conducive to the end sought.”[495] This latter construction probably defines the word “necessary” in the context of BLM’s standard lease form and the § 3101.1-2 regulation given the significant conditions the lease is subject to.

The connection in which the word “necessary” is used includes the provision in the next sentence of the modern lease forms that makes the rights granted subject to applicable laws; the terms, conditions, and stipulations found in the lease; regulations and formal orders in place when the lease is issued; and regulations and formal orders issued afterward if not inconsistent with the lease rights granted.[496] The § 3101.1-2 regulation adds to or elaborates on this list by providing that the rights granted are subject to stipulations attached to the lease; specific, nondiscretionary statutes; and “such reasonable measures as may be required by the authorized officer to minimize adverse impacts.”[497] Therefore, the context of any rights granted is that they have been made conditional on compliance with an array of external authorities, and what is “necessary” should be interpreted in this context. As discussed in detail above, many of these external sources of authority that have been incorporated into the lease include mandatory obligations to protect the environment that are imposed on BLM, the lessee, or both.[498]

Accordingly, the term “necessary” should not be viewed as strongly limiting BLM’s retained rights. Lessees can take actions to access the oil and gas and to build related improvements only to the extent these activities can be conducted in a manner that is in compliance with the substantial reservations of authority found in the lease. What is necessary is better viewed as being defined by actions that are “appropriate” or “proper” in light of what the rights granted are subject to rather than an absolute right to pursue any activity that is desired by the lessee.[499]

B. Breach and Repudiation of Contract Claims

Perhaps the ultimate limit on efforts by BLM to exert its retained rights would be a successful claim by a lessee asserting BLM had repudiated the lease contract or breached it through the actions it took, with attendant monetary damages awarded. A repudiation of a contract occurs when there is a “statement by the obligor to the obligee indicating that the obligor will commit a breach that would of itself give the obligee a claim for damages for total breach” or “a voluntary affirmative act which renders the obligor unable or apparently unable to perform without such a breach.”[500] A total breach is defined as a breach that “so substantially impairs the value of the contract to the injured party at the time of the breach that it is just in the circumstances to allow him to recover damages based on all his remaining rights to performance.”[501]

Probably the most significant case that has considered the issue of repudiation and breach of contract in the context of federal oil and gas leases was Mobil Oil, although it considered offshore leases issued pursuant to the OCSLA, not onshore Mineral Leasing Act leases. In Mobil Oil the government entered into lease contracts with the petitioners for oil exploration and development off the coast of North Carolina.[502] Due to provisions in the later-enacted Outer Banks Protection Act (OBPA)[503] that prohibited approval of required exploration, development, and production plans until specified new requirements were met, the government refused to approve an exploration plan within a specified timeline and placed the leases in suspension.[504] On these facts the Supreme Court ruled a repudiation of contract had occurred and awarded the petitioners compensation.[505]
The Court’s analysis provides guidance as to when repudiation or breach of a federal oil and gas lease contract might be deemed to occur.

The contracts at issue in Mobil Oil provided the leases were “subject to” several statutory and regulatory provisions, and the Court recognized that these provisions “in effect were incorporated into the contracts.”[506] However, the Court refused to allow the later-enacted OBPA to control these leases, because it determined the OBPA was not a statute the leases were made subject to.[507] Besides the fact that the OBPA was not a statute referenced in the lease contracts, the Court also determined that the “catchall provision” specifying the leases were subject to applicable statutes and regulations did not extend to the later-enacted OBPA and the leases were not subject to the later-enacted OBPA.[508] The Court found that without a contractual limitation on the government’s ability to impose “new and different requirements,” such as those in the newly-enacted OBPA, the companies would have received “next to nothing” when they entered into the leases.[509]

Mobil Oil teaches that care must be exercised in attempting to incorporate later-adopted regulations and statutes into a lease. The provision in modern leases that the lease is made subject to applicable laws likely includes only laws in existence when the lease is issued. The only regulations that a lease may be subject to, whether in existence at lease formation or adopted afterward, are “the Secretary of the Interior’s regulations and formal orders” as specifically provided for in the modern lease forms.[510] Nevertheless, Mobil Oil does not teach that BLM will be greatly limited in exercising its retained rights.

The Court in Mobil Oil recognized that the statutes and regulations referenced in the leases contained terms “which in effect were incorporated into the contracts” and that these “made clear that obtaining the necessary permissions [to conduct postlease activities] might not be an easy matter.”[511] Furthermore, the Court did not hold that later-adopted statutes or regulations could never be made part of a lease contract; it only held the leases created a promise not to impose new approval procedures and standards beyond those in the underlying statues and regulations in effect when the leases were executed and which had been specifically incorporated into the leases.[512] While acknowledging that the lease contracts “gave the companies rights to explore for, and to develop oil,” the Court also pointed out that

the need to obtain Government approvals so qualified the likely future enjoyment of the exploration and development rights that the contract,
in practice, amounted primarily to an opportunity to try to obtain exploration and development rights in accordance with the procedures and under the standards specified in the cross-referenced statutes and regulations.[513]

Under the facts in Mobil Oil, the Court determined this “gateway” had been significantly narrowed by the government’s actions and thus determined that a repudiation had occurred.[514] But if the government does not deviate significantly from the procedures and standards stated in the contract or incorporated into it when it is initially formed, a breach is unlikely to be found.

Given that 35,256 of the 48,342 currently active leases in the eleven western states have been issued since 1984 when the “applicable laws” language was introduced (see Table 1), that many of the “applicable laws” were adopted prior to 1980, and that BLM’s oil and gas operating regulations have been in place in nearly their present form since 1982 (and the relevant land use authorization regulations since 1981), it seems likely that most BLM oil and gas leases will survive claims that BLM actions pursuant to these authorities are a repudiation. More generally, so long as BLM takes care not to make leases worth “next to nothing,” its actions are unlikely to constitute a breach of contract. It must ensure that the gateway for seeking approval of activities on the lease is not so substantially narrowed that the legal regime that served as the basis for the bargained for right to explore for and extract oil and gas is lost or significantly altered. But given the significant number of conditions that an onshore lease is subject to, as in Mobil Oil, BLM oil and gas leases represent an opportunity to seek approval for development, not an unqualified right. As long as that opportunity is not entirely foreclosed BLM should be within its rights to demand protection of the environment, and no breach or repudiation of the contract would occur.

C. Reasonable Measures

The import of the term “reasonable measures,” which appears in section 6 of the modern lease forms as well as in the § 3101.1-2 regulation, was discussed above.[515] If a narrow view—such as that indicated in the
200-meter 60-day rule—were adopted, it could limit BLM’s ability to effectively assert its retained rights under an onshore oil and gas lease. But, as discussed,[516] a narrow interpretation seems unfounded. Section 6 of the modern lease form provides that reasonable measures are those “deemed necessary by lessor” and the regulation provides these measures are “as may be required by the authorized officer.”[517] Both the modern lease form and the § 3101.1-2 regulation state that reasonable measures within BLM’s discretion may include, but are not limited to, modification of the siting or design of facilities and timing of operations so long as they are consistent with the lease rights granted.[518] Moreover, the § 3101.1-2 regulation provides that the limits stated in the 200-meter 60-day rule are “[a]t a minimum” of what is consistent with lease rights.[519] Consequently, it seems unlikely that the discretion to impose reasonable measures on lease operations would be construed in such a narrow manner as to greatly limit BLM’s retained rights to condition development. This view is supported by recent IBLA precedent.[520]

D. Courts Have Found BLM Cannot Completely Prohibit Development
When It Issues a Non-No Surface Occupancy Lease, Which Represents
an Irreversible and Irretrievable Commitment of Resources That
Requires Compliance with NEPA

The federal courts have held that when BLM and the Forest Service engage in oil and gas leasing activities that do not preclude surface disturbance, they make an irreversible and irretrievable commitment of resources that triggers NEPA requirements because the government has committed itself to allowing some level of disturbance.[521] The leases at issue have not provided for “no surface occupancy;” the leases have been “non‑NSO” leases.[522] This view of the nature of an oil and gas lease could limit BLM’s ability to exercise its retained rights because the vast majority of federal onshore leases are non-NSO.

In Sierra Club v. Peterson, concerning a BLM and Forest Service leasing action on roadless lands in the Targhee and Bridger-Teton National Forests in Idaho and Wyoming, the D.C. Circuit determined that, with respect to the non-NSO leases that were challenged, “[e]ven assuming, arguendo, that all lease stipulations are fully enforceable, once the land is leased the Department no longer has the authority to preclude surface disturbing activities even if the environmental impact of such activity is significant.”[523] Consequently, preparation of an EIS was necessary to support the leasing decision.[524] In Conner v. Burford, involving leasing on Forest Service lands with important wildlife and natural values in Montana, the Ninth Circuit determined that the sale of non-NSO leases “constitutes the point of commitment; after the lease is sold the government no longer has the ability to prohibit potentially significant inroads on the environment.”[525] So, again, preparation of an EIS was necessary prior to leasing.[526] In Bob Marshall Alliance v. Hodel, the Ninth Circuit reached the same conclusion with respect to leasing on “wild, mountainous terrain” in the Lewis and Clark National Forest in Montana.[527]

More recently, in Northern Alaska Environmental Center v. Kempthorne (Northern Alaska),[528] involving the National Petroleum Reserve in Alaska, the Ninth Circuit again ruled that leasing represented an irretrievable commitment of resources and thus required preparation of an EIS.[529] But in this case, the court held that a parcel-by-parcel NEPA analysis was not required because impacts were unidentifiable at the leasing stage on a parcel-by-parcel basis.[530] The United States Court of Appeals for the
Tenth Circuit, in New Mexico ex rel. Richardson v. BLM,[531] also concluded that issuing an oil and gas lease without an NSO stipulation in a biologically diverse Chihuahuan Desert grassland can constitute an irretrievable commitment of resources and thus require site-specific NEPA analysis prior to lease issuance. The court recognized that “[b]ecause BLM could not prevent the impacts resulting from surface use after a lease issued, it was required to analyze any foreseeable impacts of such use before committing the resources.”[532] The IBLA has reached the same conclusions.[533]

While these cases have clearly determined that when BLM issues leases that do not include an NSO stipulation it has committed itself to allowing some level of development, these rulings probably will not greatly limit BLM’s ability to exercise its retained rights to protect the natural environment. In the majority of these cases, the leasing decisions implicated many lease parcels and thousand of acreas of public land were at issue.[534] The question before these courts was whether an EIS was needed before this far-reaching action could be taken when the leases did not preclude surface occupancy.[535] The courts concluded that an EIS was required if the leases being issued were non-NSO because the courts did not believe any reservation of authority was sufficient to assure impacts would be insignificant for purposes of NEPA over the the numerous lease parcels and large areas at issue.[536] But this determination of the need for NEPA compliance when a Federal leasing action affects public land does not necessarily stand for the proposition that BLM cannot limit development as needed on specific lease parcels. In fact, in most of these cases the courts recognized that BLM still retained rights to protect the environment, even if development could not be entirely precluded on all leases.[537]

In Sierra Club the court recognized that mitigation measures could be required, but because surface disturbance could not be absolutely precluded, it determined BLM needed to prepare an EIS.[538] In Conner, the court recognized that reasonable regulation of surface-disturbing activities was allowed but again determined this did not assure impacts would be reduced to insignificance for purposes of NEPA, and it therefore required an EIS to be prepared at the leasing stage.[539] In Northern Alaska the court concluded that, although surface disturbance could not be precluded,
“[t]he government can condition permits for drilling on implementation of environmentally protective measures, and we assume it can deny a specific application altogether if a particularly sensitive area is sought to be developed and mitigation measures are not available.”[540]

The extent of BLM’s retained rights in the context of non-NSO leases garnered discussion in a challenge to BLM and Forest Service compliance with the ESA at the leasing stage in Wyoming Outdoor Council v. Bosworth.[541] In Wyoming Outdoor Council the district court found that when the reservations of authority in the § 3101.1-2 regulation as well as the requirements related to APDs and the need for NEPA compliance at the APD stage were considered, “these reservations and procedural hurdles demonstrate that while the lessee clearly has a legal right to apply for permission to conduct oil and gas operations, his right to development of the lease parcel is far from certain.”[542] Thus, while there may be a need to prepare an EIS at the leasing stage so as to comply with NEPA, especially when numerous parcels or large areas are approved for lease sales and development cannot be absolutely precluded on all the leases, BLM still retains substantial rights to condition development on particular parcels, up to and including the prohibition of development in some circumstances.

E. Takings Claims

I have interacted with a number of BLM field personnel throughout Wyoming on a number of oil and gas projects. In response to a suggestion to assert BLM’s retained rights, BLM field personnel have sometimes commented that such action could be challenged as an illegal “taking” and BLM is limited in its rights due to this perceived barrier. The U.S. Constitution provides that “no private property be taken for public use, without
just compensation.”[543] This prohibition on the federal government “taking” property without just compensation is, however, unlikely to be a basis for successfully asserting legal claims against the government if it asserts its retained rights under an oil and gas lease.

Generally speaking, if claims were made against the government if it asserted its retained rights, those claims would likely have to be based on breach of contract claims, not constitutional takings claims. In a case challenging BLM actions related to onshore oil and gas leases issued in Wyoming, the Federal Court of Claims observed that “the concept of a taking as a compensable claim theory has limited application to the relative rights of party litigants when those rights have been voluntarily created by contract.”[544] “Ordinarily, the government’s interference with contractual rights arising under a contract with the government will give rise to a breach of contract action rather than a taking claim.”[545] And, as discussed, when the Supreme Court considered challenges to the government’s actions affecting offshore leases in Mobil Oil, the Court addressed the matter as a question of contract law, not constitutional law.[546]

Despite this general principal, concurrent takings claims can be pursued if the property right that is asserted is not governed by the terms of the contract.[547] Thus, while it is unlikely that takings claims will generally have viability because the standard lease contract has reduced the parties’ agreement to writing, it is possible a takings claim might be viable if the lessee can identify a property interest that has been interfered with that is not governed by the contract. But such claims would seem to have a remote chance of widespread success given the apparent comprehensive nature of BLM oil and gas leases.[548] To the extent a regulatory taking claim was successfully advanced, the Supreme Court has developed an extensive body of law specifying what is required to establish that a Fifth Amendment regulatory taking has occurred.[549]

F. Lessees Must Exercise Diligence to Develop Leases

Under section 4 of the modern lease forms, the lessee “must exercise reasonable diligence in developing and producing.”[550] Under section 2(j) of the 1954, 1965, and 1971 lease forms, the lessee agrees “[t]o exercise reasonable diligence in drilling and producing the wells herein provided for.”[551] The Mineral Leasing Act also requires reasonable diligence in the operation of leased property.[552] Moreover, a lessee can be required to develop wells “in accordance with good economic operating practices” and must ensure that drainage of oil and gas from a lease is not occurring due to development on adjacent leases.[553]

It is conceivable that these obligations to pursue production could limit or at least get in the way of BLM’s asserting retained rights to protect the natural environment. Nevertheless, these provisions do not specifically limit BLM’s retained rights or modify other obligations BLM operates under, so in all likelihood these requirements will have little impact on BLM’s exercise of its retained rights. And if development is essentially mandated or if BLM perceives a need to require development, it is more likely that BLM will be forced to assert its retained rights because development might occur in areas where there was otherwise less interest in pursuing development.

G. Split Estate Issues

BLM manages approximately 58 million acres of land where the surface is privately owned but the federal government owns the rights to the minerals underlying the land.[554] These lands are called split estates.[555]
While BLM operates under many of the same legal requirements on split estate lands as it does on lands wholly owned by the federal government (the oil and gas lease forms used on split estates do not differ from those used in other situations), and enjoys many of the same legal rights, the simple fact that the surface is privately owned—often by a rancher or farmer whose family has lived on the land for several generations—could affect how BLM asserts its retained rights.[556]

BLM guidance provides that it must fulfill the requirements of NEPA, the National Historic Preservation Act, the ESA, the Clean Water Act, and “other applicable laws” when it engages in permitting on split estates.[557]
The guidance states that during permit review, BLM “offers the surface owner the same level of resource protection provided on federally owned surface.”[558] Additionally, BLM will also invite the surface owner to on-site inspections, seek the owner’s input on development and reclamation issues, carefully consider the surface owner’s views and the effects on the surface owner’s use of the land “before determining mitigation requirements and approving operations,” and carefully consider the surface owner’s views on reclamation requirements and seek concurrence that final reclamation is satisfactory.[559] Consequently, while BLM enjoys the same retained rights on split estates that it enjoys elsewhere and may well exercise those rights, it is equally clear that the private surface owner will exert a strong influence over the measures that BLM prescribes. Overall, it is probably unlikely that BLM will require lesser environmental protections on split estate lands than on wholly federally owned lands, but it is possible that its approach to exerting its retained rights will differ on split estate lands.

VIII. Means by Which BLM Can Exercise Its Retained Rights

In this Part, I will briefly describe some of the means by which BLM could exercise its retained rights on federal onshore oil and gas leases. This will not be an exhaustive review; the goal is only to give the reader a sense of the options that are available to BLM to protect the natural environment. Undoubtedly more options exist than those that will be discussed. I will also present several policy changes BLM might consider that would make it better able to exercise its retained rights.

A. Options Available for Regulating Oil and Gas Development on the Public Lands That Would Help Protect the Natural Environment

BLM has substantial authority to regulate the time, place, and manner of oil and gas development.[560] It can regulate the siting of development, the design of facilities, and the timing of operations.[561] It can specify the rates of oil and gas development and production.[562] There is no doubt BLM can specify the conditions of oil and gas development on a federal onshore lease to a considerable degree.

One of the most important means by which environmental values can be protected is by requiring phased or paced development in environmentally sensitive areas. This is an “obvious” way to manage oil and gas development, according to the IBLA.[563] In Montana, the federal district court found that an EIS that had not considered phased development for coal bed methane development in Montana’s portion of the Powder River Basin failed to meet the requirements of NEPA.[564] Using this approach BLM can ensure that development activities are staggered over time, or take place in prescribed areas, until reclamation and other measures of environmental recovery indicate development can proceed in other areas.

Another important means to achieve environmental protection is to require clustered development and the related measure of directional drilling. Directional drilling, also called horizontal, deviated, or slant drilling, allows for hydrocarbon deposits that are not directly under a well pad to be accessed.[565] Using this technology, it is possible to concentrate wells on a more limited number of well pads yet still reach the oil and gas, which reduces the environmental impacts of drilling.[566] The technology and practicality of directional drilling is improving and at this point hydrocarbon deposits several thousand feet, and even more, from a well pad can be reached.[567] On the Pinedale Anticline natural gas field in western Wyoming, directional drilling will allow for thirty-two wells to be drilled from a single, consolidated well pad.[568]

Lease suspension is another means at BLM’s disposal to ensure environmental protection is achieved in leased areas. As has been discussed, both the Mineral Leasing Act and BLM’s supporting regulations allow BLM to suspend lease operations “in the interest of conservation,” as do terms in BLM’s leases.[569] One court has held that “suspending operations to avoid environmental harm is definitely a suspension in the interest of conservation in the ordinary sense of the word.”[570] Suspending leases so as to protect the natural environment is a recognized means to protect the natural environment, having been employed by BLM in the Jack Morrow Hills and Pinedale Anticline areas in Wyoming, for example.[571]

Another mechanism that could be utilized to protect environmentally sensitive areas is unitization of leases. When a group of leases are “unitized,” the leases can be maintained in force through the drilling and operation of a few, or even one, well which reduces pressure on lessees to drill or produce on their individual leases so as to maintain them in effect.[572] More efficient management is possible when a group of leases are managed collectively (unitized) rather than individually. Unitization can allow for lease holders to enjoy the benefits of a lease while achieving protection of sensitive areas. Pursuing unitization allows for orderly development with less infrastructure and disturbance, while helping to eliminate concerns such as those related to drainage of oil and gas from a lease, which sometimes creates pressure to develop a lease. BLM has authority to require unitization pursuant to section 4 of the modern leases.[573] The 1954, 1965, and 1971 leases also allow for unitization to be required.[574]

BLM can exert its retained rights by other means, including the imposition of reasonable measures,[575] conditions of approval,[576] best management practices (BMPs),[577] and the retention and enforcement of lease stipulations.[578] These conditions could affect an array of practices related to the time, place, or manner of oil and gas development. Examples include limiting the size of well pads, requiring “closed-loop” drilling fluid systems to control hazardous chemicals, using remote (computerized) means to monitor well conditions, requiring carpooling and other traffic reduction measures, requiring “liquids gathering systems” (piping hydrocarbons and perhaps produced water from scattered well locations to a centralized gathering facility so as to reduce activity at individual wells),[579] and requiring netting to be placed over “reserve” (waste) pits so as to protect birds, bats, and other wildlife. A number of additional measures could be added to this list, including, but not limited to, requiring “green completions” to reduce air pollution when wells are brought into production following drilling, dust control measures, the use of protective mats to reduce surface disturbance when drilling is occurring, using existing roads and minimizing the level of road construction used to access well pads, and reinjecting produced water rather than disposing of it on the surface. Assuring effective reclamation with native plant species (especially shrubs such as sagebrush (Artemesia)) is also important. BLM has developed a website devoted to BMPs, and these measures should be vigorously employed.[580] The University of Colorado Law School has also developed a website devoted to BMPs applicable to oil and gas development and these too can be employed.[581]

One of the most important means by which BLM can protect the natural environment is to ensure that stipulations oriented toward the protection of wildlife and other resources are not abandoned and are, in fact, vigorously enforced. In Wyoming, BLM has shown an increasing tendency to eliminate these important protections, to grant exceptions and waivers to them,
or both.[582] This is an unfortunate trend that should not be perpetuated if protection of other resources is desired.[583]

Other options that could be considered by BLM when operations are proposed in sensitive areas include pursuing lease buyout and trade. Lease buyout likely would require the approval of Congress, not to mention congressional authorization of funding, but lease trades could be pursued administratively by BLM if a company was willing to exchange its leases.

B. Policy Changes

BLM could make several policy changes which would enable it to better exert its retained rights so as to ensure protection of the natural environment. While, as argued above, the 200-meter 60-day rule establishes a floor to the reasonable measures BLM can require, not a ceiling,[584] this provision in the § 3101.1-2 regulation is nevertheless sometimes treated by BLM as imposing limits on its discretion.[585] The § 3101.1-2 regulation should therefore be rewritten to eliminate the 200-meter 60-day rule. The provision stating that reasonable measures deemed consistent with the lease rights granted “[a]t a minimum” include limitations that do not “require relocation of proposed operations by more than 200 meters; require that operations be sited off the leasehold; or prohibit new surface disturbing operations for a period in excess of 60 days in any lease year”[586] creates tension with the prior two sentences in the regulation. The first sentence provides that reasonable measures to minimize adverse impacts can be imposed “as may be required by the authorized officer,” and then the next sentence states, “Such reasonable measures may include, but are not limited to, modification to siting or design of facilities, timing of operations, and specification of interim and final reclamation measures.”[587] This tension should be eliminated from the regulation, and BLM should simply provide for taking reasonable measures as it deems necessary to minimize adverse impacts, consistent with the lease rights granted.[588]

BLM should also take action to ensure IM 92-67 and similar provisions in BLM Manual MS-3101 have no continuing force.[589] While the IM nominally expired in 1992, it seems to have some continuing influence over BLM oil and gas development decision making.[590] And the manual section has no stated expiration date.[591] In particular, the requirement that the need for stipulations or conditions of approval “must be clearly and convincingly documented” or that there be “clear evidence and convincing need” for a condition of approval should be eliminated.[592] This elevated burden of proof is not justified.[593] BLM decision making regarding what measures are needed to minimize adverse impacts when it approves oil and gas development should be subject to the arbitrary and capricious standard that applies to all agency actions, not a heightened clear and convincing evidence standard.[594]

It would also be useful if BLM developed regulations defining what constitutes “unnecessary or undue degradation” (UUD) in the context of oil and gas development, as it has done for hardrock minerals.[595] Given the importance of this “specific, nondiscretionary statute” under FLPMA[596] it would be helpful to have a formal definition of what constitutes UUD in the context of oil and gas development. As recognized in Mineral Policy Center, any such regulation should recognize that both unnecessary degradation of the public lands and undue degradation of the lands must be prevented.[597] Provisions related to unnecessary degradation could prevent activities that are not necessary for mining while the undue degradation prong of any regulation should prevent excessive or unwarranted harm to the public lands.[598] The numerous environmental protection laws applicable to oil and gas development on the public lands could help define what impacts are excessive or unwarranted.

More generally, BLM should consider issuing IMs that fully explain BLM’s retained rights and its authority to exercise its retained rights so as to protect the natural environment. Likewise, the Secretary of the Interior or the Interior Department Solicitor should consider issuing similar orders or opinions. The extent of BLM’s retained rights should be fully explained and apparent in agency policy.

In October 2009, BLM issued a report regarding seventy-seven lease parcels in Utah that had been offered for sale at the December 2008 lease sale but were withdrawn due to court action and other controversy.[599]
In this report the agency made a number of recommendations for improvement of its leasing program with regard to the Utah lease parcels.[600] One recommendation made by the reviewing team of BLM and other agency personnel was this: “BLM and others would benefit by guidance from the Solicitor’s Office on the nature of the right created by issuance of a lease.”[601] The team noted that it had heard varying opinions expressed by personnel in the BLM Utah state office regarding what rights were granted by a lease, ranging from views that a lease was a “compensable property right” that could only be extinguished by paying just compensation, to views that a lease is a “contingent right” that could be extinguished.[602] There were also various opinions expressed regarding what level of development constituted enjoyment of lease rights.[603] The review team concluded that “[t]he nature of a lease right is a fundamental issue that underlies the Bureau’s oil and gas leasing program.”[604] The findings and differences of opinion in the report emphasize the need for formal statements from BLM via IMs, or from the Department of Interior via Solicitor’s opinions or Secretarial orders, regarding the nature of the rights granted under a federal onshore oil and gas lease, and, just as importantly, the rights that BLM retains and will exert despite having issued a lease.

Any BLM IMs and Department of the Interior Solicitor opinions or Secretarial orders related to BLM’s retained rights could be made part of the oil and gas reform effort the Department of the Interior is now pursuing.[605]
In particular, they could support or be a component of the Master Leasing and Development Plans that will now be required.[606]

IX. BLM Has an Obligation to Fully Assert Its Retained Rights

In this Article I have largely expressed the degree of BLM’s retained rights under an oil and gas lease and its ability to exercise them in somewhat conditional terms. BLM “has” retained rights; it “can” or even “should” exercise them, but I generally have not said BLM must exert those retained rights. In this Part, however, I will argue BLM must fully exert its retained rights and I will explain the basis for this view.

Fundamentally, it is my view that not only does BLM have retained rights allowing it to protect the natural environment in areas where it has issued an oil and gas lease that grants the right to develop those minerals, it in fact has an obligation to fully assert those rights. The reason I take this view is because many of the authorities that the right to develop has been made subject to are stated in mandatory terms or establish specific, nondiscretionary obligations.

Under the Mineral Leasing Act, BLM “shall” regulate surface disturbing activities in the interest of conservation of surface resources.[607]
Under FLPMA, BLM “shall” take any action necessary to prevent unnecessary or undue degradation of the public lands.[608] Under the ESA, BLM “shall” further the purposes of the ESA, “shall” ensure its actions do not jeopardize the continued existence of listed species or destroy or adversely modify their critical habitat, and it is unlawful for BLM to take a listed species.[609] The National Historic Preservation Act, Migratory Bird Treaty Act, and the Bald and Golden Eagle Protection Act contain various mandatory requirements or prohibitions.[610] The Clean Air Act and Clean Water Act provide that federal agencies “shall” be subject to laws for the control and abatement of air and water pollution.[611] A number of other applicable laws discussed in Part V.B are also framed in mandatory terms.

Many of BLM’s oil and gas operating regulations related to protection of the natural environment are also mandatory.[612] For example, in approving oil and gas operations, BLM is directed to protect natural resources and environmental quality and operators are subject to a number of other obligations (which BLM is charged with enforcing). BLM’s land-use authorization regulations require mandatory terms and conditions for the protection of a number of environmental attributes and benefits.[613] Some of the terms and conditions in the lease forms are stated in mandatory terms, especially in modern versions of the lease. Section 6 of the modern leases in use since March 1984 provides that lessees “shall” (or “must”) take reasonable measures to minimize adverse impacts to the environment, with the determination of what is reasonable being as “deemed necessary by lessor to accomplish the intent of this section.”[614] Provisions in Onshore Oil and Gas Order Number 1 include mandatory obligations for BLM.[615]

Modern versions of the lease form make any rights granted under the lease subject to these various mandatory conditions.[616] The § 3101.1-2 regulation contains a similar provision making the lease rights granted subject to stipulations attached to the lease; specific, nondiscretionary statutes; and reasonable measures required by the authorized officer to minimize adverse impacts.[617] It seems clear that BLM is obliged to meet a number of mandatory requirements for environmental protection under the terms of a federal onshore oil and gas lease and the authorities that have been incorporated into it.

This is not to say these mandatory obligations eliminate or override BLM’s obligation to manage the public lands for multiple use and sustained yield[618] or to meet the energy development goals expressed in several statutes and BLM’s regulations.[619] Assertion of its retained rights relative to environmental protection will have to be done in recognition of these obligations. But it is equally clear that the mineral policies of this country have been formulated in recognition of a need for substantial environmental protection. Accordingly, when BLM issues an oil and gas lease it does not grant an unqualified right to development. It has retained many rights to condition development so as to protect the natural environment. And many of these retained rights are grounded in mandatory environmental protection obligations.

It is not my contention that a successful “failure to act” lawsuit charging violation of § 706(1) of the Administrative Procedure Act could necessarily be launched against BLM in order to force it to assert particular retained rights.[620] One court rejected this proposition with respect to BLM’s operations regulations.[621] Rather, my contention is that BLM has substantial retained rights allowing it to protect the environment when oil and gas operations are proposed on an onshore lease, and given the mandatory nature of many of the underlying authorities that have been incorporated into the lease, it must fully exert those retained rights, even if the agency retains discretion to determine exactly what those measures might be.[622]

Given the wide array of mandatory provisions requiring strong measures to protect the environment, which attach to a lease and govern lease operations, it is clear that not only does BLM have discretion to condition lease development and operations pursuant to its retained rights in order to protect the natural environment, it in fact has an obligation to
do so, even if the details of what those actions might be remain within
BLM’s discretion.

X. Conclusion

There are approximately 39,000,000 acres of federal mineral estate in the eleven western states subject to onshore oil and gas leases issued by the Bureau of Land Management. The leases grant the lessee the right to extract any oil or natural gas that may be found on the leased land. However, the leases also make the grant of rights subject to a number of reservations of authority to the federal government. The rights that BLM retains stem from laws, regulations, terms in the lease contract, and other authorities. A review of the provisions in these authorities shows that BLM retains substantial rights to regulate the time, place, and manner of oil and gas development, despite having granted rights allowing oil and gas development. Development can be conditioned through regulation of the siting and design of facilities and the timing of operations, as well as specification of the rates of oil and gas development and production so as to minimize adverse impacts to the environment, other resource values, land uses, and land users. If BLM fully exercises this array of retained rights it can considerably reduce environmental disturbance caused by oil and gas development on the public lands. Given the mandatory, nondiscretionary nature of many of the authorities that a federal onshore oil and gas lease is subject to, BLM has an obligation to fully exert its retained rights.



* The author is program director and a staff attorney with the Wyoming Outdoor Council. He has a B.S. degree in wildlife biology, an M.S. degree in range science, and received his J.D. from the University of Utah College of Law. He would like to thank Rebekah Smith for her assistance with research supporting this Article during her tenure as an intern with the Wyoming Outdoor Council during the summer of 2008. He would also like to thank Sara Waterson for her assistance in generating the data that appear in the table in this Article and other background data. Thanks is also due to the BLM personnel who are mentioned in the Article and who kindly offered helpful (and in some cases critical) information and materials. And finally, the author would like to thank Lisa Dardy McGee, a staff attorney with the Wyoming Outdoor Council, and Timothy J. Preso, a staff attorney with Earthjustice, who reviewed a draft of this Article and made helpful suggestions that improved it greatly. The author can be reached at bruce@wyomingoutdoorcouncil.org.

[1] SeeBureau of Land Mgmt., U.S. Dep’t of the Interior, Public Land Statistics 2008 tbl.1-3 (2008), available at http://www.blm.gov/public_land_statistics/pls08/pls1-3_08.pdf [hereinafter Bureau of Land Mgmt., Public Land Statistics 2008]; Bureau of Land Mgmt., U.S. Dep’t of the Interior, Total Number of Acres Leased, http://www.blm.gov/pgdata/etc/
medialib/blm/wo/MINERALS__REALTY__AND_RESOURCE_PROTECTION_/energy/oil___gas_statistics.Par.16715.File.dat/chart_2009_02.pdf. These data do not reflect oil and gas leasing on tribal lands. See Bureau of Land Mgmt., U.S. Dep’t of the Interior, Facts About Federal Energy Leasing and Development, http://www.blm.gov/wo/st/en/info/newsroom/Energy_Facts_07.html (last visited Apr. 18, 2010) (pointing out that nationwide the Bureau of Land Management manages nearly 700 million acres of federal mineral estate).

[2] See 43 C.F.R. pts. 3100, 3160 (2008) (presenting BLM’s onshore oil and gas leasing and oil and gas operations regulations).

[3] See Bureau of Land Mgmt., Public Land Statistics 2008, supra note 1, tbl.1-3.

[4] See Bureau of Land Mgmt., U.S. Dep’t of the Interior, BLM-Alaska Energy Program, http://www.blm.gov/ak/st/en/prog/energy.html (last visited Apr. 18, 2010) (presenting information on BLM oil and gas leasing in Alaska).

[5] The Forest Service must consent to leasing on its lands, although BLM conducts the actual leasing. See Mineral Leasing Act, 30 U.S.C. § 226(h) (2006) (providing that leasing by the Secretary of the Interior on Forest Service lands cannot occur over the objection of the Secretary of Agriculture); 43 C.F.R. § 3101.7-1(c) (2008) (same); 36 C.F.R. §§ 228.100–.116 (2009) (presenting the Forest Service’s oil and gas resource regulations).

[6] 43 U.S.C. §§ 1331–1356 (2006). For a description of the Minerals Management Service’s offshore leasing program, see Minerals Mgmt. Serv., U.S. Dep’t of the Interior, Offshore Energy & Minerals Management, http://www.mms.gov/offshore (last visited Apr. 18, 2010).

[7] 30 U.S.C. §§ 181–287 (2006).

[8] Id.

[9] 30 U.S.C. §§ 22–24, 26–30, 33–35, 37, 39–43, 47 (2006).

[10] Id. § 29.

[11] Id. § 23.

[12] 30 U.S.C. § 181 (2006).

[13] Id. §§ 181, 184(d), 188–189, 191, 226(b)–(c).

[14] Id. § 226(a) (emphasis added). In a line of cases, numerous courts have held that the decision to issue a lease in the first instance is a decision within the Secretary of the Interior’s discretion. See, e.g., Udall v. Tallman, 380 U.S. 1, 4 (1965); United States ex rel. McLennan v. Wilbur, 283 U.S. 414, 417 (1931); McDonald v. Clark, 771 F.2d 460, 463 (10th Cir. 1985); McTiernan v. Franklin, 508 F.2d 885, 887 (10th Cir. 1975); Duesing v. Udall, 350 F.2d 748, 750 (D.C. Cir. 1965); Cont’l Land Res., 162 I.B.L.A. 1, 7 (2004). But see Mountain States Legal Found. v. Hodel, 668 F. Supp. 1466, 1474 (D. Wyo. 1987) (finding that delay in processing leasing proposals can constitute an impermissible withdrawal of public lands); Mountain States Legal Found. v. Andrus, 499 F. Supp. 383, 391 (D. Wyo. 1980) (same). In Bob Marshall Alliance v. Hodel, 852 F.2d 1223 (9th Cir. 1988), the United States Court of Appeals for the Ninth Circuit declined to follow the holding in Andrus relative to withdrawals. Id. at 1229–30.

[15] 30 U.S.C. § 226(b)(1)(A) (2006).

[16] Id.

[17] Id. § 226(c)(1).

[18] Id. § 226(f)–(h).

[19] Federal Onshore Oil and Gas Leasing Reform Act of 1987, Pub. L. No. 100-203, 101 Stat. 1330-256 (codified as amended at 30 U.S.C. §§ 195, 226-3 (2006)).

[20] 30 U.S.C. § 226(b)–(h) (2006).

[21] Act of Feb. 25, 1920, ch. 85, § 17, 41 Stat. 437, 443 (1920) (current version at 30 U.S.C. § 181(b) (2006)).

[22] Act of Aug. 8, 1946, ch. 916, § 3, 60 Stat. 950, 951 (1946) (current version at 30 U.S.C. § 181(c) (2006)).

[23] 4 George Cameron Coggins & Robert L. Glicksman, Public Natural Resources Law § 39:2, at 39-6 (2d ed. 2010).

[24] Id. at 39-6 to -7. “SIMO” stands for “simultaneous lease drawing,” but according to BLM officials the abbreviation is really a shortened reference to “simultaneous.” Telephone Interview with William Gewecke, Petroleum Eng’r, Minerals & Realty Mgmt., Bureau of Land Mgmt.
(Nov. 12, 2009).

[25] Patricia J. Beneke, The Federal Onshore Oil and Gas Leasing Reform Act of 1987:
A Legislative History and Analysis
, 4 J. Min. L. & Pol’y 11, 15 (1988).

[26] Id.

[27] Id. at 17–25.

[28] Id. at 35–37.

[29] See generally id. at 11; Thomas L. Sansonetti & William R. Murray, A Primer on the Federal Onshore Oil and Gas Leasing Reform Act of 1987 and Its Regulations, 25 Land & Water L. Rev. 375 (1990); Abraham E. Haspel, Drilling for Dollars: The New and Improved Federal Oil Lease Program, Reg., Fall 1990, at 62.

[30] 734 F.2d 347 (8th Cir. 1984) (determining that KGS determinations on the Fort Chaffee Military Reservation in Arkansas were arbitrarily constrained, allowing lands to be inappropriately leased on a noncompetitive basis in an area with strong competition for productive oil and gas properties).

[31] Telephone Interview with Julie Weaver, Chief, Branch of Fluid Minerals Adjudication, Wyo. State Office, Bureau of Land Mgmt. (Oct. 15, 2009).

[32] Id.

[33] Id. According to Ms. Weaver, in older leases there can be some differences in rental provisions when a lease was in a KGS or in a unitized field, and sometimes different royalty provisions can apply. Id. But there are no differences in the environmental protection provisions in competitive versus noncompetitive leases or in pre- versus post-FOOGLRA leases. Id.

[34] In New Mexico ex rel. Richardson v. Bureau of Land Mgmt. (Richardson), 565 F.3d 683 (10th Cir. 2009), the United States Court of Appeals for the Tenth Circuit construed the BLM oil and gas development process as being comprised of three stages: land use planning, leasing, and filing an APD. Id. at 689 n.1, 716. However, I believe the five-step process I describe captures the nuances of the oil and gas leasing and development process; moreover, the court did note that “exploring” needed to occur. Id. at 689 n.1.

[35] 43 U.S.C. §§ 1701–1785 (2006); see id. § 1712 (presenting FLPMA’s planning requirements); 43 C.F.R. pt. 1600 (2008) (presenting BLM’s regulations implementing FLPMA’s planning requirements).

[36] Richardson, 565 F.3d at 689 n.1.

[37] The RMP for a BLM field office can be found on that field office’s website. For example, the RMP for the Pinedale, Wyoming field office can be found on that field office’s website. Pinedale Field Office, Bureau of Land Mgmt., Record of Decision/Approved RMP, http://www.blm.gov/wy/st/en/programs/Planning/rmps/pinedale/rod_armp.html (last visited
Apr. 18, 2010).

[38] See, e.g., Bureau of Land Mgmt., U.S. Dep’t of the Interior, Arizona Resource Management Plans, http://www.blm.gov/az/st/en/info/nepa/environmental_library/arizona_resource_
management.html (last visited Apr. 18, 2010) (providing draft and final RMPs for the Arizona state office).

[39] See, e.g., Pinedale Field Office, Bureau of Land Mgmt., U.S. Dep’t of the Interior, Record of Decision and Approved Pinedale Resource Management Plan 2-1 tbl.1-1 (2008), available at http://www.blm.gov/pgdata/etc/medialib/blm/wy/programs/planning/rmps/ pinedale/rod.Par.45058.File.dat/05_Record_of_Decision_and_Approved_Pinedale_RMP.pdf; id. map 1-3, available at http://www.blm.gov/pgdata/etc/medialib/blm/wy/programs/planning/
rmps/pinedale/rod/maps.Par.50090.File.dat/03_Map1-03.pdf. Areas available for lease can be examined using the GeoCommunicator tool at Bureau of Land Mgmt. & U.S. Forest Serv.,
U.S. Dep’t of the Interior & U.S. Dep’t of Agric., GeoCommunicator Home, http://www.geocommunicator.gov (last visited Apr. 18, 2010).

[40] National Environmental Policy Act of 1969, 42 U.S.C. §§ 4321–4347 (2006).

[41] See id. § 4332(2)(C) (2006) (requiring preparation of an EIS when a federal action may significantly affect the quality of the human environment); 43 C.F.R. § 1601.0-6 (2008) (“Approval of a resource management plan is considered a major Federal action significantly affecting the quality of the human environment.”).

[42] Beneke, supra note 25, at 43.

[43] See infra notes 75–81 and accompanying text (discussing lease protests).

[44] See, e.g., Sierra Club v. Peterson, 717 F.2d 1409, 1414 (D.C. Cir. 1983) (quoting Mobil Oil Corp. v. Fed. Trade Comm’n, 562 F.2d 170, 173 (2d Cir. 1977)) (holding that issuing an oil and gas lease without a no surface occupancy stipulation represents an irreversible and irretrievable commitment of resources, which requires compliance with NEPA); Richardson, 565 F.3d 683, 718 (10th Cir. 2009) (same); Conner v. Burford, 848 F.2d 1441, 1449–50 (9th Cir. 1988) (same); Ctr. for Native Ecosystems, 170 I.B.L.A. 331, 344–45 (2006). These and other cases will be discussed in Part VII.D, infra.

[45] 43 C.F.R. pt. 3150 (2008).

[46] See 40 C.F.R. §§ 1501.3–.4, 1508.9 (2009) (presenting Council on Environmental Quality regulations governing when to prepare an EA versus an EIS and requirements for these two types of documents); id. pt. 1502 (2009) (same).

[47] See Gates Rubber Co. v. Comm’r, 74 T.C. 1456, 1460 (1980).

[48] Rocky Mountain Oil & Gas Ass’n v. Watt, 696 F.2d 734, 742 (10th Cir. 1982).

[49] See National Environmental Policy Act of 1969, 42 U.S.C. § 4332(2) (2006) (making NEPA applicable to all federal agencies, of which BLM is one); id. § 4332(2)(C) (requiring an EIS for all federal agency actions significantly affecting the quality of the human environment).

[50] See, e.g., Bureau of Land Mgmt., U.S. Dep’t of the Interior, Record of Decision for the Jonah Infill Drilling Project: Environmental Impact Statement 1 (2006), available at http://www.blm.gov/pgdata/etc/medialib/blm/wy/information/NEPA/pfodocs/jonah.Par.5187.File.dat/00rod2.pdf [hereinafter Bureau of Land Mgmt., Jonah Infill ROD] (approving 3100 wells); Bureau of Land Mgmt., U.S. Dep’t of the Interior, Record of Decision: Final Supplemental Environmental Impact Statement for the Pinedale Anticline Oil and Gas Exploration and Development Project 4 (2008), available at http://www.blm.gov/pgdata/etc/medialib/blm/wy/
information/NEPA/pfodocs/anticline/rod.Par.50775.File.dat/00ROD.pdf [hereinafter Bureau of Land Mgmt., Pinedale Anticline ROD] (approving 4399 wells); Bureau of Land Mgmt., U.S. Dep’t of the Interior, Record of Decision: Environmental Impact Statement for
the Atlantic Rim Natural Gas Field Development Project 1 (2006), available at http://www.blm.gov/pgdata/etc/medialib/blm/wy/information/NEPA/rfodocs/atlantic_rim/rod.Par.46558.File.dat/ROD.pdf [hereinafter Bureau of Land Mgmt., Atlantic Rim EIS] (approving approximately 2000 wells); see also Theodore Roosevelt Conservation P’ship v. Salazar, 605 F. Supp. 2d 263, 269 (D.D.C. 2009) (deciding in a challenge to the Atlantic Rim project that BLM did not violate NEPA or FLPMA).

[51] See supra note 50.

[52] See Bureau of Land Mgmt., U.S. Dep’t of the Interior, Record of Decision for the Designation of Areas of Critical Environmental Concern for the Roan Plateau: Resource Management Plan Amendment and Environmental Impact Statement 1 (2008), available at http://www.blm.gov/pgdata/etc/medialib/blm/co/programs/land_use_planning/rmp/roan_plateau/documents.Par.3928.File.dat/FinalRoanRODII_3_13_08.pdf.

[53] 43 C.F.R. § 3162.3-1(c) (2008).

[54] Id.

[55] See S. Utah Wilderness Alliance, 159 I.B.L.A. 220, 224 (2003).

[56] Pub. L. No. 109-58, 119 Stat. 604 (codified primarily in scattered sections of 42 U.S.C.)

[57] See 42 U.S.C. § 15942(a), (b)(1)–(4) (2006) (presenting the Energy Policy Act of 2005’s categorical exclusions). In September 2009, the United States Government Accountability Office (GAO) released a report entitled Energy Policy Act of 2005: Greater Clarity Needed to Address Concerns with Categorical Exclusions for Oil and Gas Development Under Section 390 of the Act. U.S. Gov’t Accountability Office, Energy Policy Act of 2005: Greater Clarity Needed to Address Concerns with Categorical Exclusions for Oil and Gas Development Under Section 390 of the Act (2009), available at http://www.gao.gov/new.items/d09872.pdf. The GAO found that 6100 out of 22,000 APDs, or 28%, that had been filed between 2006 and 2008 were approved via categorical exclusion from NEPA. Id. at 12. Categorical exclusions were also used in another 1150 instances. Id. at “Highlights” (unnumbered page). The GAO also found that the use of categorical exclusions often was not in compliance with section 390 of the Energy Policy Act or BLM guidance on the use of categorical exclusions. Id. at 23. The report recommends that Congress take action to amend section 390 so as to clarify certain key terms, and that BLM take interim action to provide better oversight and guidance on the use of categorical exclusions. Id. at 53. BLM indicated to the GAO that it will take immediate steps to ensure the use of section 390 categorical exclusions are consistent with the Energy Policy Act of 2005 and BLM guidance. Id. at 54. The Forest Service has also adopted a categorical exclusion from NEPA for oil and gas development projects. 36 C.F.R. § 220.6(e)(17) (2009). This categorical exclusion is not based on the Energy Policy Act of 2005 categorical exclusions and is a separate Forest Service policy. See National Environmental Policy Act Procedures, 73 Fed. Reg. 43,084, 43,090–91 (July 24, 2008) (codified at 36 C.F.R. pt. 220). Issues related to Energy Policy Act of 2005 categorical exclusions will be considered further infra in the text accompanying notes 221–23.

[58] Mineral Leasing Act, 30 U.S.C. § 226(f) (2006).

[59] See W. Org. of Res. Councils v. Bureau of Land Mgmt., 591 F. Supp. 2d 1206, 1208
(D. Wyo. 2008) (reviewing a BLM decision to allow up to 51,000 coal bed methane wells in the Powder River Basin); Bureau of Land Mgmt., Jonah Infill ROD, supra note 50, at 1; Bureau of Land Mgmt., Pinedale Anticline ROD, supra note 50, at 4.

[60] See S. Utah Wilderness Alliance, 177 I.B.L.A. 284, 284–85 (2009); Gas Gathering Agreement in Powder River Basin: Coal Bed Methane Project Reached Between
Pennaco Energy and TransMontaigne Unit, Bear Paw Energy Inc.
, Bus. Wire, Mar. 24, 1999, http://findarticles.com/p/articles/mi_m0EIN/is_1999_March_24/ai_54191657 (last visited
Apr. 18, 2010); Press Release, Nat’l Trust for Historic Pres., Coalition Applauds
Bureau of Land Management for Withdrawing Eight Parcels of Land Near Chaco Canyon, New Mexico from Oil and Gas Lease Sale (Oct. 9, 2009), http://www.preservationnation.org/about-us/press-center/press-releases/2009/coalition-applauds-bureau-of.html (last visited Apr. 18, 2010); ExxonMobil, Colorado: Piceance Basin, http://www.exxonmobil.com/corporate/energy_project_ piceance.aspx (last visited Apr. 18, 2010).

[61] 30 U.S.C. § 226(a)–(e) (2006); 43 C.F.R. pt. 3100 (2008).

[62] Bureau of Land Mgmt., U.S. Dep’t of the Interior, Oil and Gas, http://www.blm.gov/wo/st/
en/prog/energy/oil_and_gas.html (last visited Apr. 18, 2010); see also Sansonetti & Murray, supra note 29, at 385–403 (discussing, among other things, the leasing process).

[63] See, e.g., Bureau of Land Mgmt., U.S. Dep’t of the Interior, Competitive Lease Sale Notices & Results, http://www.blm.gov/wy/st/en/programs/energy/Oil_and_Gas/Leasing.html (last visited Apr. 18, 2010) (presenting Wyoming oil and gas lease sale information).

[64] 30 U.S.C. § 226(b)(1)(A) (2006); 43 C.F.R. §§ 3110.1(b), 3120.1-1 to -2 (2008).

[65] 30 U.S.C. § 226(b)(1)(A), (c) (2006); 43 C.F.R. §§ 3110.1(b), 3120.6 (2008).

[66] 30 U.S.C. § 226(b)(1)(A) (2006); 43 C.F.R. §§ 3110.1(b), 3120.6 (2008).

[67] 30 U.S.C. § 226(b)(1)(A) (2006); 43 C.F.R. §§ 3110.3-3(b), 3120.2-3 (2008).

[68] 30 U.S.C. § 226(e) (2006); 43 C.F.R. §§ 3107.2-1, 3107.3-1, 3110.3-1, 3120.2-1 (2008).

[69] 30 U.S.C. § 226(e) (2006); 43 C.F.R. § 3107.1 (2008).

[70] 30 U.S.C. § 226(d) (2006); 43 C.F.R. § 3103.2-2(a) (2008).

[71] 30 U.S.C. § 226(b)(1)(A), (c) (2006); 43 C.F.R. § 3103.3-1(a)(1) (2008).

[72] 30 U.S.C. § 191(a) (2006).

[73] 43 C.F.R. § 3104.1(a) (2008).

[74] Id. §§ 3104.2, 3104.3(a)–(b).

[75] Id. §§ 3110.4(a), 3120.5-1(a)–(b), 3120.5-2, 3120.5-3(a).

[76] Id. §§ 3110.3-2, 3120.2-2.

[77] Id. §§ 4.450-2, 3120.1-3; see also Bureau of Land Mgmt., U.S. Dep’t of the Interior, Notice of Competitive Oil and Gas Lease Sale, at i–ii, viii–ix (2009), available at http://www.blm.gov/
pgdata/etc/medialib/blm/wy/programs/energy/og/leasing/2009.Par.62062.File.dat/12list.pdf
(presenting information on BLM’s competitive oil and gas lease sale on December 1, 2009,
in Wyoming and describing protest procedures).

[78] Bureau of Land Mgmt., supra note 77, at vi.

[79] Id. at ix.

[80] Id.

[81] Id.; 43 C.F.R. §§ 4.410(a), 3120.1-3 (2008). However, an appeal to the IBLA is not subject to an automatic stay while the appeal is considered, so lease parcels can be issued after a protest is rejected even if an appeal is filed. See id. § 3120.1-3 (providing that “[n]o action pursuant to the regulations in this subpart shall be suspended under § 4.21(a) of this title due to an appeal from a decision by the authorized officer to hold a lease sale” and also providing that the authorized officer “may” suspend a lease on a parcel while considering a protest or appeal).

[82] 43 C.F.R. § 3101.1-1 (2008).

[83] See Bureau of Land Mgmt., U.S. Dep’t of Interior, Form 3100-11, Offer to Lease and Lease For Oil and Gas 1 (2008), available at http://www.blm.gov/pgdata/etc/medialib/blm/mt/
blm_programs/energy/oil_and_gas/leasing/lease_sales/2009/jan.Par.6548.File.dat/3100-11.pdf.

[84] Mailed Copies of Lease Forms from Karen Wrenn, Forms Manager, Denver Office,
Bureau of Land Mgmt., to Rebekah Smith (Aug. 13, 2008) (on file with author). These forms included versions published in 1984, 1988, 1992, 2003, and 2006. Bureau of Land Mgmt.,
U.S. Dep’t of Interior, Form 3100-11, Offer to Lease and Lease for Oil and Gas (1984) [hereinafter Bureau of Land Mgmt., 1984 Lease Form]; Bureau of Land Mgmt., U.S. Dep’t of Interior, Form 3100-11, Offer to Lease and Lease for Oil and Gas (1988) [hereinafter Bureau of Land Mgmt., 1988 Lease Form]; Bureau of Land Mgmt., U.S. Dep’t of Interior,
Form 3100-11, Offer to Lease and Lease for Oil and Gas (1992) [hereinafter Bureau of Land Mgmt., 1992 Lease Form]; Bureau of Land Mgmt., U.S. Dep’t of Interior, Form 3100-11, Offer to Lease and Lease for Oil and Gas (2003) [hereinafter Bureau of Land Mgmt., 2003 Lease Form]; Bureau of Land Mgmt., U.S. Dep’t of Interior, Form 3100-11, Offer to Lease and Lease for Oil and Gas (2006) [hereinafter Bureau of Land Mgmt., 2006 Lease Form].

[85] Bureau of Land Mgmt., 1984 Lease Form, supra note 84.

[86] See sources cited supra note 84.

[87] See Bureau of Land Mgmt., supra note 83.

[88] Mailed Copies of Lease Forms from Vickie Mistarka, Wyo. State Office, Bureau of Land Mgmt., to author (Feb. 2009) (on file with author). These forms included versions in use in 1954, 1965, and 1971. Bureau of Land Mgmt., U.S. Dep’t of Interior, Form 4-1158, Offer to Lease and Lease for Oil and Gas (1954) [hereinafter Bureau of Land Mgmt., 1954 Lease Form]; Bureau of Land Mgmt., U.S. Dep’t of Interior, Form 4-1158, Offer to Lease and Lease for Oil and Gas (1965) [hereinafter Bureau of Land Mgmt., 1965 Lease Form]; Bureau of Land Mgmt., U.S. Dep’t of Interior, Form 3120-19, Lease for Oil and Gas (1971) [hereinafter Bureau of Land Mgmt., 1971 Lease Form].

[89] See sources cited supra note 88. The 1954 lease was issued on Form 4-1158 (fourth edition), dated September 1953; the 1965 lease was issued on Form 4-1158 (ninth edition), dated August 1961; and the 1971 lease was issued on Form 3120-19, dated May 1968.

[90] Id.

[91] The time period the lease is presumed to have been in effect is based on an example of a lease that was issued on July 9, 1954, provided by the BLM Wyoming state office. This lease form is dated September 1953, but it is assumed similar leases were in effect from the enactment of the Mineral Leasing Act in 1920 through the date of this lease.

[92] The time period the lease is presumed to have been in effect is based on an example of a lease that was issued on January 20, 1965, provided by the BLM Wyoming state office. This lease form is dated August 1961, but it is assumed similar leases were in effect from the date of the 1954 lease through the date of this lease.

[93] The time period the lease is presumed to have been in effect is based on an example of a lease that was issued on March 29, 1971, provided by the BLM Wyoming state office. This lease form is dated May 1968, but it is assumed similar leases were in effect from the date of the 1965 lease through the date of the first lease available in BLM’s archives, which is March 1984.

[94] This and the subsequent lease forms are available in BLM’s archives, so the dates this lease and the subsequent leases were in effect can be determined with assurance and is not presumed.

[95] These data were generated from BLM’s LR2000 database. Bureau of Land Mgmt.,
U.S. Dep’t of the Interior, Bureau of Land Management’s Land & Mineral Legacy Rehost
2000 System–LR 2000, http://www.blm.gov/lr2000/ (last visited Apr. 18, 2010). A search was done for all currently active oil and gas leases within the different time frames by state in the
11 western states.

[96] In addition to granting the right to develop oil and gas, the leases also make provisions for other matters not directly implicating BLM’s retained rights relative to protection of the natural environment. These include provisions for payment of rentals, royalties, and bonds, among other things. See Bureau of Land Mgmt., supra note 83, at 1.

[97] Bureau of Land Mgmt., 1954 Lease Form, supra note 88, at 1.

[98] Bureau of Land Mgmt., 1965 Lease Form, supra note 88, at 1; Bureau of Land Mgmt., 1971 Lease Form, supra note 88, at 1.

[99] Bureau of Land Mgmt., 1984 Lease Form, supra note 84, at 1.

[100] Bureau of Land Mgmt., 1988 Lease Form, supra note 84, at 1; Bureau of Land Mgmt., 1992 Lease Form, supra note 84, at 1; Bureau of Land Mgmt., 2003 Lease Form, supra note 84, at 1; Bureau of Land Mgmt., 2006 Lease Form, supra note 84, at 1; Bureau of Land Mgmt., supra note 83, at 1. The “exclusive right” to develop all of the oil and gas that might be found on a lease should probably be viewed as creating a right for the lessee to ensure no other entity seeks to develop oil and gas on a lease, not as creating rights against the government that could prevent it from exercising its retained rights. An exclusive right is “[o]ne which only the grantee thereof can exercise, and from which all others are prohibited or shut out.” Black’s Law Dictionary 565 (6th ed. 1990).

[101] Bureau of Land Mgmt., 1954 Lease Form, supra note 88, at 2.

[102] Id.

[103] Id.

[104] Id.

[105] Id.

[106] Id.

[107] Id.

[108] Bureau of Land Mgmt., 1965 Lease Form, supra note 88.

[109] Bureau of Land Mgmt., 1971 Lease Form, supra note 88, at 2.

[110] See Bureau of Land Mgmt., supra note 83.

[111] Bureau of Land Mgmt., 1984 Lease form, supra note 84, at 1.

[112] Bureau of Land Mgmt., 1988 Lease form, supra note 84, at 1; Bureau of Land Mgmt., 1992 Lease Form, supra note 84, at 1; Bureau of Land Mgmt., 2003 Lease Form, supra note 84, at 1; Bureau of Land Mgmt., 2006 Lease Form, supra note 84, at 1; Bureau of Land Mgmt., supra note 83, at 1.

[113] See, e.g., Bureau of Land Mgmt., 1971 Lease Form, supra note 88, at 1.

[114] Bureau of Land Mgmt., supra note 83, at 2.

[115] Bureau of Land Mgmt., 1984 Lease Form, supra note 84, at 2; Bureau of Land Mgmt., 1988 Lease Form, supra note 84, at 2; Bureau of Land Mgmt., 1992 Lease Form, supra note 84, at 2; Bureau of Land Mgmt., 2003 Lease Form, supra note 84, at 2; Bureau of Land Mgmt., 2006 Lease Form, supra note 84, at 3; Bureau of Land Mgmt., supra note 83, at 3.

[116] Bureau of Land Mgmt., 1984 Lease Form, supra note 84, at 2; Bureau of Land Mgmt., 1988 Lease Form, supra note 84, at 2; Bureau of Land Mgmt., 1992 Lease Form, supra note 84, at 2; Bureau of Land Mgmt., 2003 Lease Form, supra note 84, at 2; Bureau of Land Mgmt., 2006 Lease Form, supra note 84, at 3; Bureau of Land Mgmt., supra note 83, at 3.

[117] Bureau of Land Mgmt., 1984 Lease Form, supra note 84, at 1.

[118] Bureau of Land Mgmt., 1984 Lease Form, supra note 84, at 1; Bureau of Land Mgmt., 1988 Lease Form, supra note 84, at 1; Bureau of Land Mgmt., 1992 Lease Form, supra note 84, at 1; Bureau of Land Mgmt., 2003 Lease Form, supra note 84, at 1.

[119] Bureau of Land Mgmt., 1984 Lease Form, supra note 84, at 2; Bureau of Land Mgmt., 1988 Lease Form, supra note 84, at 2; Bureau of Land Mgmt., 1992 Lease Form, supra note 84, at 2; Bureau of Land Mgmt., 2003 Lease Form, supra note 84, at 2.

[120] Bureau of Land Mgmt., 1984 Lease Form, supra note 84, at 2; Bureau of Land Mgmt., 1988 Lease Form, supra note 84, at 2; Bureau of Land Mgmt., 1992 Lease Form, supra note 84, at 2; Bureau of Land Mgmt., 2003 Lease Form, supra note 84, at 2.

[121] Bureau of Land Mgmt., 1984 Lease Form, supra note 84, at 2; Bureau of Land Mgmt., 1988 Lease Form, supra note 84, at 2; Bureau of Land Mgmt., 1992 Lease Form, supra note 84, at 2; Bureau of Land Mgmt., 2003 Lease Form, supra note 84, at 2.

[122] Compare Bureau of Land Mgmt., 1984 Lease Form, supra note 84, at 2, Bureau of Land Mgmt., 1988 Lease Form, supra note 84, at 2, Bureau of Land Mgmt., 1992 Lease Form, supra note 84, at 2, and Bureau of Land Mgmt., 2003 Lease Form, supra note 84, at 2, with Bureau of Land Mgmt., 2006 Lease Form, supra note 84, at 3, and Bureau of Land Mgmt., supra note 83.

[123] Compare Bureau of Land Mgmt., 2006 Lease Form, supra note 84, at 3, and Bureau of Land Mgmt., supra note 83, at 3, with Bureau of Land Mgmt., 1984 Lease Form, supra note 84, at 2, Bureau of Land Mgmt., 1988 Lease Form, supra note 84, at 2, Bureau of Land Mgmt., 1992 Lease Form, supra note 84, at 2, and Bureau of Land Mgmt., 2003 Lease Form, supra
note 84, at 2.

[124] Compare Bureau of Land Mgmt., 1984 Lease Form, supra note 84, at 2, Bureau of Land Mgmt., 1988 Lease Form, supra note 84, at 2, Bureau of Land Mgmt., 1992 Lease Form, supra note 84, at 2, and Bureau of Land Mgmt., 2003 Lease Form, supra note 84, at 2, with Bureau of Land Mgmt., 2006 Lease Form, supra note 84, at 3, and Bureau of Land Mgmt., supra note 83.

[125] Compare Bureau of Land Mgmt., 1984 Lease Form, supra note 84, at 2, Bureau of Land Mgmt., 1988 Lease Form, supra note 84, at 2, Bureau of Land Mgmt., 1992 Lease Form, supra note 84, at 2, and Bureau of Land Mgmt., 2003 Lease Form, supra note 84, at 2, with Bureau of Land Mgmt., 2006 Lease Form, supra note 84, at 3, and Bureau of Land Mgmt., supra note 83.

[126] Gutierrez de Martinez v. Lamagno, 515 U.S. 417, 432–33 n.9 (1995).

[127] The American Heritage Dictionary of the English Language 1160 (4th ed. 2000).

[128] Id. at 1598.

[129] Black’s Law Dictionary 1019 (6th ed. 1990).

[130] Id. at 1375.

[131] Id.

[132] See 27A Words and Phrases 663–90 (2007 & Supp. 2009) (presenting constructions of “must”); 39 id. at 173–229 (2006 & Supp. 2009) (presenting constructions of “shall”).

[133] See, e.g., Bureau of Land Mgmt., 1954 Lease Form, supra note 88, at 2; Bureau of Land Mgmt., 1971 Lease Form, supra note 88, at 2.

[134] Bureau of Land Mgmt., 1954 Lease Form, supra note 88, at 2; Bureau of Land Mgmt.,
1965 Lease Form, supra note 88, at 2; Bureau of Land Mgmt., 1971 Lease Form, supra note 88, at 2.

[135] See, e.g., Bureau of Land Mgmt., supra note 83, at 3.

[136] Id.

[137] Id.

[138] Id. at 1.

[139] 43 C.F.R. § 3101.1-2 (2008).

[140] Oil and Gas Leasing, Geothermal Resources Leasing, 53 Fed. Reg. 17,340, 17,352
(May 16, 1988).

[141] 43 C.F.R. § 3101.1-2 (2008) (emphasis added).

[142] Id. § 3100.0-5(d).

[143] See discussion infra Parts V.B–C.

[144] 43 C.F.R. § 3101.1-2 (2008).

[145] Id.

[146] Id.

[147] See, e.g., Bureau of Land Mgmt., U.S. Dep’t of the Interior, BLM Manual Handbook 3110-1, Oil and Gas Adjudication Handbook: Issuance of Leases §§ 3101.06.B, 3101.06.B.1, 3101.12 (1996) (on file with the author) (stating that conditions of approval will impose requirements “by not more than” the limitations in the 200-meter 60-day rule); Pinedale Field Office, Bureau of Land Mgmt., Draft Environmental Impact Statement for the Pinedale Resource Management Plan app. 7, at A7-1 (2007), available at http://www.blm.gov/pgdata/etc/medialib/blm/wy/programs/planning/rmps/pinedale/deis/appendices.Par.48971.File.dat/Appendix07.pdf (“[T]he [standard lease terms] allow the authorized officer to move a well or other facility up to 200 meters or delay operations for up to 60 days in a year.”); Instruction Memorandum No. WY-2010-12 from State Dir., Wyo. State Office,
Bureau of Land Mgmt., to Dist. Managers & Deputy State Dirs. 12 (Dec. 29, 2009), available at http://www.blm.gov/pgdata/etc/medialib/blm/wy/resources/efoia/IMs/2010.Par.61358.File.dat/

wy2010-012.pdf (presenting the BLM Wyoming state office Instruction Memorandum regarding sage-grouse conservationand stating, “BLM may, to some degree, exceed the siting and timing limitations set forth in 43 C.F.R. § 3101.1-2”).

[148] 43 CFR § 3101.1-2 (2008).

[149] Oil and Gas Leasing, Geothermal Resources Leasing, 53 Fed. Reg. 17,340, 17,341
(May 16, 1988).

[150] Id.

[151] Id.

[152] See id.; Bureau of Land Mgmt., 1984 Lease Form, supra note 84, at 2.

[153] Yates Petroleum Corp., 176 I.B.L.A. 144, 156 (2008).

[154] Id.

[155] Instruction Memorandum No. 92-67 from Dir., Bureau of Land Mgmt., to All State Dirs. (Dec. 3, 1991) (on file with the author).

[156] Id. at 1.

[157] Federal Land Policy and Management Act of 1976, 43 U.S.C. § 1732(b) (2006).
The implications of the FLPMA requirement to prevent unnecessary or undue degradation will be considered further infra in Part V.B.3.

[158] Instruction Memorandum No. 92-67 from Dir. to All State Dirs., supra note 155, at 3.

[159] Id. at 2.

[160] Id.

[161] Id. at 4; Bureau of Land Mgmt., supra note 147, § 3101.06.

[162] Bureau of Land Mgmt., supra note 147, § 3101.06.B.2.

[163] 43 C.F.R. § 3101.1-2 (2008).

[164] Bureau of Land Mgmt., supra note 83, at 3.

[165] 43 C.F.R. § 3101.1-2 (2008); Bureau of Land Mgmt., supra note 83, at 3.

[166] Oil and Gas Leasing, Geothermal Resources Leasing, 53 Fed. Reg. 17,340, 17,341
(May 16, 1988).

[167] Yates Petroleum Corp., 176 I.B.L.A. 144, 155 (2008) (citing 43 C.F.R. § 3101.1-2 and Federal Land Policy and Management Act of 1976, 43 U.S.C. § 1732(b) (2006)).

[168] Id. at 156 (“‘[T]he authority of the Bureau to prescribe ‘reasonable,’ but more stringent, protection measures is not affected by the final rulemaking.’” (alteration in original) (quoting
53 Fed. Reg. at 17,340–41)).

[169] See id.

[170] IM 92-67 expired by its own terms on September 30, 1992. Instruction Memorandum No. 92-67 from Dir. to All State Dirs., supra note 155, at 1. That said, IMs can continue to be treated as operative by BLM even after they nominally expire. See, e.g., Yates Petroleum Corp.,
176 I.B.L.A. at 159 n.16 (pointing out that in the request for state director review decision under consideration in that appeal, “IM No. WY-90-231 expired on Sept. 30, 1991, [but] it is BLM practice to continue to use the guidance contained in the memorandum”). BLM has sometimes continued to cite the need for clear and convincing evidence to support its ability to condition development long after IM 92-67 expired. See Bureau of Land Mgmt, U.S. Dep’t of the Interior, Final Environmental Impact Statement for the Jack Morrow Hills Coordinated Activity Plan/Proposed Green River Resource Management Plan app. 4, at A4-1 (2004), available at http://www.blm.gov/pgdata/etc/medialib/blm/wy/field-offices/rock_springs/jmhcap/
2004final/vol2.Par.9991.File.dat/106app04.pdf (stating that conditions of approval not provided for by stipulation must be documented through analysis that “must provide clear and convincing evidence showing that undue and unnecessary degradation would result if the [condition of approval] were not applied”). Consequently, IM 92-67 is of continuing concern; BLM Manual MS-3101 has no stated expiration date.

[171] Bureau of Land Mgmt., supra note 83, at 1.

[172] 43 C.F.R. § 3101.1-2 (2008).

[173] Bureau of Land Mgmt., supra note 83, at 1.

[174] Id.

[175] Id. at 1; see also 43 C.F.R. § 3101.1-2 (2008) (providing that the lease is made subject to “[s]tipulations attached to the lease”).

[176] Bureau of Land Mgmt., supra note 83, at 1.

[177] Id.

[178] 43 C.F.R. § 3101.1-2 (2008).

[179] Id.; see Bureau of Land Mgmt., supra note 83, at 3 (providing in section six that the lessee must take reasonable measures deemed necessary by the lessor to minimize adverse impacts).

[180] 43 C.F.R. § 3101.1-2 (2008); Bureau of Land Mgmt., supra note 83, at 1.

[181] 373 U.S. 472 (1963).

[182] Id. at 477–78 (citation omitted) (holding that the Secretary of the Interior has broad administrative powers allowing him to cancel a lease he determined was improperly issued); accord Udall v. Tallman, 380 U.S. 1, 19 (1965) (“An oil and gas lease does not vest title to the lands in the lessee.” (citing Boesche, 373 U.S. at 477–78)); id. at 22 (stating that an oil and gas lease gives the lessee “no right in the land itself”).

[183] See Bureau of Land Mgmt., supra note 83, at 1.

[184] 43 C.F.R. § 3101.1-2 (2008).

[185] Oil and Gas Leasing, Geothermal Resources Leasing, 53 Fed. Reg. 17,340, 17,341–42
(May 16, 1988).

[186] Id. at 17,341.

[187] 43 C.F.R. § 3101.1-1 (2008).

[188] 53 Fed. Reg. at 17,352.

[189] See infra Part V.B.1–6.

[190] See infra Part V.B.1–6.

[191] But see Bureau of Land Mgmt., supra note 147, § 3101.12.B (stating that with respect to specific, nondiscretionary laws, “the requirements of the law shall be met by all oil and gas leases regardless of when the leases were issued”).

[192] Mineral Leasing Act, 30 U.S.C. §§ 181, 226(a)–(c) (2006); see discussion supra Parts II, III.A–B.

[193] 30 U.S.C. § 187 (2006) (emphasis added).

[194] However, the Supreme Court said in a case involving leases “located in a mouth of the Mississippi River” in Louisiana that the Mineral Leasing Act “controls in some measure the actual use of the leased tract, to promote goals such as conservation and safety,” but did not identify particular language in 30 U.S.C. § 187 supporting this view. Wallis v. Pan Am. Petroleum Corp., 384 U.S. 63, 64, 69 (1966).

[195] 30 U.S.C. § 189 (2006).

[196] See Arch Mineral Corp. v. Lujan, 911 F.2d 408, 415 (10th Cir. 1990) (recognizing in a coal leasing case that § 189 “is a broad grant of authority”); Getty Oil Co. v. Clark, 614 F. Supp.
904, 916 (D. Wyo. 1985) (“This provision grants the Secretary broad powers and authority commensurate with the broad responsibilities imposed upon his office.”), aff’d sub nom.
Texaco Producing, Inc., 84 F.2d 776 (10th Cir. 1988).

[197] See discussion infra Part V.D.1.a–b.

[198] 30 U.S.C. § 189 (2006).

[199] Id. § 209 (emphasis added); see also 43 C.F.R. § 3103.4-4 (2008) (providing a companion regulatory provision authorizing suspension of all operations and production on a lease “in the interest of conservation of natural resources”).

[200] 653 F.2d 595 (D.C. Cir. 1981).

[201] 614 F. Supp. 904 (D. Wyo. 1985).

[202] Copper Valley Machine Works, Inc., 653 F.2d at 600 (determining that the “ordinary meaning” of the term “in the interest of conservation” in § 209 of the Mineral Leasing Act allows suspension of operations so as to avoid environmental harm); Getty Oil Co., 614 F. Supp. at 916–17
(holding § 189 and § 209 of the Mineral Leasing Act provide broad grants of authority allowing conditioning of development to protect the environment, even allowing denial of drilling operations to protect wilderness values when a suspension is requested by the lessee).

[203] 30 U.S.C. § 226(g) (2006) (emphasis added) (requiring further that a “plan of operations” exist before a drilling permit can be issued and that bonding be in place “to ensure the complete and timely reclamation of the lease tract, and the restoration of any lands or surface waters adversely affected by lease operations after the abandonment or cessation of oil and gas operations on the lease”).

[204] Federal Onshore Oil and Gas Leasing Reform Act of 1987, Pub. L. No. 100-203, § 5102(g), 101 Stat. 1330, 1330-257 to -258 (codified as amended at 30 U.S.C. § 226(g) (2006)); see supra notes 19–20 and accompanying text (discussing the enactment of FOOGLRA).

[205] See Robertson v. Methow Valley Citizens Council, 490 U.S. 332, 348, 350 (1989) (stating that “[s]ection 101 of NEPA declares a broad national commitment to protecting and promoting environmental quality,” but holding “it is now well settled that NEPA itself does not mandate particular results, but simply prescribes the necessary process”); 40 C.F.R. § 1500.1 (2009) (providing that NEPA “is our basic national charter for protection of the environment”).

[206] National Environmental Policy Act of 1969, 42 U.S.C. § 4332 (2006). The continuing policy of the federal government is “to use all practicable means and measures” to achieve three stated goals, one of which is “to create and maintain conditions under which man and nature can exist in productive harmony.” Id. § 4331(a).

[207] Id. § 4331(b) (providing that all practicable means are to be used to achieve the ends of fulfilling responsibilities to succeeding generations, assuring pleasing surroundings, attaining the widest range of beneficial uses of the environment without undesirable and unintended consequences, preserving our national heritage, achieving balance that permits high standards of living and sharing of amenities, and enhancing the quality of renewable resources and achieving maximum recycling of depletable resources).

[208] See, e.g., 40 C.F.R. § 1500.2 (2009) (“Federal agencies shall to the fullest extent possible . . . [u]se all practicable means . . . to restore and enhance the quality of the human environment and avoid or minimize any possible adverse effects of their actions upon the quality of the human environment.”).

[209] Getty Oil Co., 614 F. Supp. 904, 920 (D. Wyo. 1985) (citing Flint Ridge Dev. Co. v. Scenic Rivers Ass’n, 426 U.S. 776, 787–88 (1976), aff’d sub nom. Texaco Producing, Inc., 840 F.2d 776
(10th Cir. 1988); Grindstone Butte Project v. Kleppe, 638 F.2d 100, 103 (9th Cir. 1981);
Detroit Edison Co. v. U.S. Nuclear Reg. Comm’n, 630 F.2d 450 (6th Cir. 1980)).

[210] Anglers of the Au Sable v. U.S. Forest Serv. (Au Sable), 565 F. Supp. 2d 812, 815, 818
(D. Mich. 2008).

[211] Id. at 824–33 (identifying issues related to uniqueness, controversy and uncertainty; potential for setting precedent and cumulative impacts; and impacts to endangered species as having been insufficiently considered); see 40 C.F.R. § 1508.27(b)(1)–(10) (2009) (presenting the 10 Council on Environmental Quality intensity factors that guide determination of whether an agency action will significantly affect the environment, and thus whether an EIS needs to be prepared rather than a less rigorous EA).

[212] Au Sable, 565 F. Supp. 2d at 834.

[213] Id.

[214] See discussion infra Part V.D.1.b.

[215] Au Sable, 565 F. Supp. 2d at 835.

[216] Id. at 836.

[217] Id. at 840 (citing 43 C.F.R. § 3161.2 (2008), which provides that the BLM authorized officer is directed to require that operations protect natural resources and environmental quality).

[218] Id.

[219] National Environmental Policy Act of 1969, Pub. L. No. 91-190, 83 Stat. 852 (1970) (codified as amended at 42 U.S.C. §§ 4321–4347 (2006)).

[220] See discussion supra Parts IV.D, V.A.

[221] See supra note 57 and accompanying text.

[222] See supra note 57 and accompanying text.

[223] Energy Policy Act of 2005, 42 U.S.C. § 15942(b) (2006) (making provisions in subdivisions 1 and 3 that require prior NEPA compliance before the enumerated activity can be categorically excluded from further NEPA compliance).

[224] See National Environmental Policy Act of 1969, 42 U.S.C. § 4332 (2006) (requiring compliance with NEPA for major federal actions significantly affecting the quality of the human environment); Federal Land Policy and Management Act of 1976, 43 U.S.C. § 1712 (2006) (requiring BLM to develop land use plans); 43 C.F.R. § 1601.0-6 (2008) (“Approval of a resource management plan is considered a major Federal action significantly affecting the quality of the human environment.”).

[225] 43 U.S.C. § 1701(a)(8) (2006).

[226] Id. § 1701(a)(12) (citation omitted); see infra text accompanying notes 283–84.

[227] 43 U.S.C. § 1732(a) (2006) (“The Secretary shall manage the public lands under principles of multiple use and sustained yield, in accordance with the land use plans . . . .”).

[228] Id. § 1702(c); see also id. § 1702(h) (defining “sustained yield”).

[229] Id. § 1732(b).

[230] See Bureau of Land Mgmt., supra note 147, §§ 3101.06.B.2, 3101.0