BP America Production Company v. Davis

87 F.4th 1226
CourtCourt of Appeals for the Tenth Circuit
DecidedDecember 6, 2023
Docket22-8024
StatusPublished
Cited by1 cases

This text of 87 F.4th 1226 (BP America Production Company v. Davis) is published on Counsel Stack Legal Research, covering Court of Appeals for the Tenth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
BP America Production Company v. Davis, 87 F.4th 1226 (10th Cir. 2023).

Opinion

Appellate Case: 22-8024 Document: 010110963862 Date Filed: 12/06/2023 Page: 1 FILED United States Court of Appeals PUBLISH Tenth Circuit

UNITED STATES COURT OF APPEALS December 6, 2023

Christopher M. Wolpert FOR THE TENTH CIRCUIT Clerk of Court _________________________________

BP AMERICA PRODUCTION COMPANY,

Plaintiff-Appellant,

vs. No. 22-8024

DEBRA ANNE HAALAND, in her official capacity as United States Department of Interior Secretary; KIMBRA DAVIS, in her official capacity as Office of Natural Resources Revenue Director,

Defendants-Appellees. _________________________________

Appeal from the United States District Court for the District of Wyoming (D.C. No. 2:21-CV-00105-NDF) _________________________________

Sarah Y. Dicharry of Jones Walker, LLP, New Orleans, Louisiana (Jonathan A. Hunter of Jones Walker, LLP; and Hadassah M. Reimer of Holland & Hart LLP, Jackson, Wyoming, with her on the brief), for Plaintiff-Appellant.

Justin D. Heminger (Todd Kim with him on the brief), of United States Department of Justice, Environment and Natural Resources Division, for Defendants-Appellees. _________________________________

Before PHILLIPS, BALDOCK, and McHUGH, Circuit Judges. _________________________________

PHILLIPS, Circuit Judge. _________________________________ Appellate Case: 22-8024 Document: 010110963862 Date Filed: 12/06/2023 Page: 2

BP America Production Company asks us to adopt its interpretation of

the Federal Oil and Gas Royalty Simplification and Fairness Act, which would

shield it from paying the government nearly $700,000 in correctly assessed

royalty underpayments. In doing so, BP has abandoned the sole argument it

presented to the agency—that the agency had erred about the effective date of

BP’s lease transfers. Instead, BP now argues that the royalty-payment statute

compels reversal of all individual royalty underpayments less than $10,000,

despite those underpayments being correctly calculated and assessed. We reject

BP’s statutory interpretation and affirm the district court’s order upholding the

agency order requiring BP to pay.

BACKGROUND

I. Legislative Background

In response to the “archaic and inadequate” accounting of lease royalties

by the Department of the Interior, 30 U.S.C. § 1701(a)(2), Congress passed the

Federal Oil and Gas Royalty Management Act of 1982, codified at 30 U.S.C.

§§ 1701–1759. The Royalty Management Act tasked the Secretary of the

Interior with creating an internal system for managing royalties on federal oil

and gas leases. Id. § 1701(b)(2). Congress mandated that the Secretary

“establish a comprehensive inspection, collection and fiscal and production

accounting and auditing system to provide the capability to accurately

determine oil and gas royalties.” Id. § 1711(a). Congress also permitted the

Secretary to delegate responsibility to “conduct inspections, audits, and

2 Appellate Case: 22-8024 Document: 010110963862 Date Filed: 12/06/2023 Page: 3

investigations . . . to any State with respect to all Federal land within the

State.” Id. § 1735(a); see id. § 1732(a).

The newly established Minerals Management Service (MMS) assumed

responsibility for the collection, distribution, and auditing of royalties on

federal leases. S. Rep. No. 104-260, at 13 (1996). But MMS proved more

malady than cure; it often took up to twelve years to complete audits of

production royalties. Id. at 14.

In 1996, still faced with a revenue-collection system clogged by lengthy

audits and appeals, Congress amended the Royalty Management Act as part of

its enactment of the Federal Oil and Gas Royalty Simplification and Fairness

Act of 1996 (RSFA), Pub. L. No. 104-185, 110 Stat. 1700. Among other things,

the RSFA streamlined the audit and appeals processes for royalty disputes.

S. Rep. No. 104-260, at 14. For instance, Congress imposed a seven-year

statute of limitations on all royalty disputes, barring judicial proceedings or

demands outside the limitations period. 30 U.S.C. § 1724(b)(1). And further,

Congress limited the Secretary (or the Secretary’s designee) to 33 months in

which to issue final decisions on any appealed royalty dispute after an appeal’s

commencement, id. § 1724(h)(1); otherwise, she would be “deemed” to have

approved a final decision either affirming the agency for a monetary obligation

of more than $10,000 or reversing it for a monetary obligation of $10,000 or

less, id. § 1724(h)(2).

3 Appellate Case: 22-8024 Document: 010110963862 Date Filed: 12/06/2023 Page: 4

In 2010, the Department restructured the MMS into three separate

offices, including the Office of Natural Resources Revenue (ONRR).

Reorganization of Title 30, Code of Federal Regulations, 75 Fed. Reg. 61,051,

61,052 (Oct. 4, 2010). Taking the MMS’s place, the ONRR’s duties included

determining, collecting, and auditing royalties for federal oil and gas

leases. 30 C.F.R. § 1201.100. The ONRR also became the first level of appeal

for royalty payors disputing adverse decisions from a State order. See id.

§ 1290.105.

If dissatisfied with the ONRR Director’s decision, royalty payors may

appeal to the Department of the Interior’s Board of Land Appeals (IBLA).

Id. § 1290.108; 43 C.F.R. § 4.1(b)(2). The Secretary has delegated to the IBLA

the authority to make final decisions on various matters, including “[t]he use

and disposition of public lands and their resources.” 43 C.F.R. § 4.1(b)(2)(i).

The IBLA’s Chief Administrative Judge is authorized to delegate an appeal to a

panel of two or more administrative judges and to communicate final decisions

on the IBLA’s and the Secretary’s behalf. 1 Id. § 4.2(a), (c).

II. Factual Background

Between 2008 and 2012, BP held more than twenty federal leases in the

Jonah Field, one of the largest natural-gas deposits in the United States.

1 Because the IBLA acts on the Secretary’s behalf, we refer to the IBLA and the Secretary interchangeably in our discussion.

4 Appellate Case: 22-8024 Document: 010110963862 Date Filed: 12/06/2023 Page: 5

Located on federal land in the Upper Green River Basin of west central

Wyoming, the Jonah Field is managed by the BLM, a subagency of the United

States Department of the Interior.

Sometime in early 2012, BP conveyed the record title, operating rights,

and royalty obligations for its Jonah Field leases to Linn Energy Holdings,

LLC. In the applicants’ signature block for each lease transfer form, BP and

Linn Energy marked the date as June 25, 2012, and declared, as between

themselves, the transfer to be “EFFECTIVE as of the 1st of April, 2012.” E.g.,

App. at 170. For unstated reasons, BP and Linn Energy delayed in filing the

necessary forms with the BLM to provide the BLM notice of the transfers and

seek the BLM’s necessary approval. See 43 C.F.R.

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