Medco Energi U S L L C v. Haaland

CourtDistrict Court, W.D. Louisiana
DecidedFebruary 26, 2025
Docket2:23-cv-01755
StatusUnknown

This text of Medco Energi U S L L C v. Haaland (Medco Energi U S L L C v. Haaland) is published on Counsel Stack Legal Research, covering District Court, W.D. Louisiana primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Medco Energi U S L L C v. Haaland, (W.D. La. 2025).

Opinion

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF LOUISIANA LAKE CHARLES DIVISION

MEDCO ENERGI U S L L C CASE NO. 2:23-CV-01755

VERSUS JUDGE JAMES D. CAIN, JR.

DOUG BURGUM ET AL MAGISTRATE JUDGE CAROL B. WHITEHURST

MEMORANDUM RULING

Before the court are cross-motions for summary judgment filed, respectively, by plaintiff Medco Energi US LLC (“Medco”), as predecessor in interest to Sanare Energy Partners, LLC (“Sanare”) (referred to collectively as “Plaintiff”) and by defendants Doug Burgum, Secretary of the United States Department of the Interior (“DOI”), and Howard Cantor, Director of DOI’s Office of Natural Resources Revenue (“ONRR”). Docs. 25, 27. Both motions are opposed. Docs. 27, 29. Also before the court is a Motion to Admit Exhibit 5 [doc. 32] filed by plaintiff, with opposition [doc. 34] from the government. I. BACKGROUND

A. 2017 and 2018 Fee Assessment Background This suit arises from inspection fees assessed by ONRR to plaintiff, a lessee on multiple offshore federal mineral leases in the Gulf of Mexico, in 2017 and 2018. Three leases give rise to the facility inspection fees at issue: Lease OCS-G 04909 (“MP 64”); Lease OCS-G 05692 (“MP 65”); and Lease OCS-G 05392 (“EC 317”). Nineteen installations form the MP 64 lease block. AR 229. One of these, referred to as the “A, AQ Platform,” consists of two installations containing processing and metering equipment and a separate, smaller installation containing a well (#2). /d. The three facilities are in close proximity and connected via walkways:

ri I I Bete BE er) a, eee ei oe anil i ee a = isd eae en | ; + <0 me) fas (eae ani Af ices eo i Big aur ay “li F ec eae, a ar = = ae = a ee re = = = oo EN = ole RRR Soe = ee a 2. ES ates Oe ae =o, a er Ae oe aaa AR 240. The A, AQ platform is surrounded by eighteen individual wells that tie back to this central structure via subsea flowlines. AR 229-30. These eighteen wells are supported by caissons that protrude above the waterline and contain drive pipes and small work decks for accessing the wells. /d. They range in distance from one third of a mile to over one mile from the A, AQ platform. AR 239. The following map depicts the arrangement of Medco’s wells in relation to the A, AQ platform (circled in blue) within the MP 64 lease:

Page 2 of 21

AR 238. Two views of caissons from the MP 64 block are shown below, with other caissons visible in the distance:

Page 3 of 21

rl 4 AN aD Fer i? □ ce te. ~ Sa i 5 a 7 a L “al Pan ee = a | F eR tee tk □ eect Bo oped Coed os ee peas a oo

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AR 241. Beginning with Fiscal Year 2010, Congress directed DOI to offset its appropriations with inspection fees. AR 227. From that time forward, Medco was assessed fees annually for BSEE’s inspection of 23 to 26 facilities—including the MP 64 block facilities at issue

Page 4 of 21

here. AR 527–80. At no time did ONRR or BSEE ever treat the MP 64 block as a single installation for the purposes of assessing inspection fees. See id.

B. ONRR Director Decision Medco appealed the 2017 and 2018 fee demands to the ONRR director, who consolidated the appeals. AR 96. There it asserted that (1) ONRR lacked authority to issue the invoices under the 2017 and 2018 Continuing Resolutions and (2) ONRR incorrectly categorized the well installations as separate facilities.1 AR 104–27. The ONRR director denied this appeal on January 28, 2020. AR 226. To this end ONRR determined that the

2017 and 2018 Continuing Resolutions preserved its authority to collect inspection fees, and that even if the Continuing Resolutions had not preserved this authority, the subsequent Consolidated Appropriations Acts “cured any such defect” by “specifically directing the Secretary to assess and collect the fees for fiscal years 2017 and 2018.” AR 232–33. Finally, ONRR determined that BSEE properly exercised its discretion to categorize

Medco’s well installations as separate “facilities,” despite their subsea attachments. AR 233–34. It noted that, in cases where the facilities were not connected by a walkway, “a BSEE inspector is required to locate such structures and to take a boat to separately inspect each structure,” which “results in a more complex, and time- and resource-intensive inspection and a separate inspection fee is [therefore] warranted.” AR 234. Accordingly,

the director decided that characterization of the caissons as separate facilities was

1 Medco also appealed inspection fees assessed on the East Cameron 318 lease block and on a Main Pass 55 installation. ONRR consolidated the matters and granted the appeal as to the East Cameron 318 and Main Pass 55 fees. AR 235–36. Those portions of the appeal are not at issue here. “consistent with BSEE’s long-standing practice” and that the decision must be upheld. AR 235.

C. IBLA Appeal Medco then sought review of ONRR’s decision from the Interior Board of Land Appeals (“IBLA”). IBLA issued a decision on July 14, 2021, reversing ONRR as to BSEE’s authority to collect fees under the Continuing Resolutions.2 Doc. 25, att. 1 (IBLA 199). It stated:

It is true that the continuing appropriations acts for fiscal years 2017 and 2018 authorized funding at levels sufficient to allow the Department of the Interior to operate as it did under the previous year’s consolidated appropriations act. But each of the prior consolidated appropriations acts directed the Secretary to collect inspection fees for facilities subject to inspection under the OCSLA only for a single fiscal year. For example, the fiscal year 2016 consolidated appropriations act stated: “In fiscal year 2016, the Secretary shall collect a nonrefundable inspection fee, which shall be deposited in the ‘Offshore Safety and Environmental Enforcement’ account, from the designated operator for facilities subject to inspection under 43 U.S.C. 1348(c).” The fiscal year 2017 consolidated appropriations act used identical language, except specific to fiscal year 2017. In these acts, Congress expressly limited the Secretary’s authority to collect inspection fees to a single fiscal year, and the continuing appropriations acts did not extend the Secretary’s authority into the next fiscal year. As Medco notes in its appeal, Congress could have provided authority to the Secretary to collect inspection fees in fiscal years 2017 and 2018 by including language in each of the applicable continuing appropriations acts specifically authorizing this action. But Congress did not do so. Accordingly, the continuing appropriations acts did not provide authority to the Secretary to collect the fees in ONRR’s orders for fiscal years 2017 and 2018. It was not until Congress enacted the consolidated appropriations acts for fiscal years 2017 (in May 2017) and 2018 (in March 2018) that it provided the Secretary with the authority to collect inspection fees for those fiscal years.

2 All documents in this case that post-date the ONRR director’s decision are not part of the administrative record, but the parties have agreed that the IBLA decisions and Interior Solicitor’s M-Opinion may be cited because they are publicly available legal sources and provide necessary background to the case. Id. at 10–11 (IBLA 208–09) (emphasis in original). The IBLA also concluded, contrary to the ONRR director, that the 2017 and 2018 Consolidated Appropriations Acts did not

“cure” ONRR’s lack of authority to make fee demands because the statutes lacked the express language required to indicate that they should operate retroactively. Id. at 12 (IBLA 210). D.

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Bluebook (online)
Medco Energi U S L L C v. Haaland, Counsel Stack Legal Research, https://law.counselstack.com/opinion/medco-energi-u-s-l-l-c-v-haaland-lawd-2025.