Solenex LLC v. Zinke

CourtDistrict Court, District of Columbia
DecidedSeptember 24, 2018
DocketCivil Action No. 2013-0993
StatusPublished

This text of Solenex LLC v. Zinke (Solenex LLC v. Zinke) is published on Counsel Stack Legal Research, covering District Court, District of Columbia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Solenex LLC v. Zinke, (D.D.C. 2018).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

SoLENEX LLC, ) ) Plainriff, ) ) . v. ) Civil Case No. 13-0993 (RJL) ) SALLY JEWELL et al., ) ) FILED Defendants. ) ) sEP 2 h 2018 C| k,U.S. Dl t` t&B kru tcy MEMOI!ANDUM OPIN10N wills torthe%!;inm?%.,¢.,¥,.m

(Septernbelq, 2018) [Dkts ## 89, 93]

Plaintiff Solenex LLC (“Solenex”), the holder of a federal oil and gas lease in Montana, brings suit against the Secretary of the lnterior, the Secretary of Agriculture, the Director of the Bureau of Land Management, the Chief of the Forest Service, and several other subordinate federal officials (collectively, “federal defendants” or “the Government”) relating to the Government’s cancellation of its lease after suspending all oil and gas drilling and extraction activity on that lease for more than thirty years. See First Arnend. Cornpl. [Dl

(“Pl.’s Mot.”); Defs.’ Cross-Motion for Summary Judgrnent [Dkt. # 93] (“Defs.’ Mot.”).

For the following reasons, the Court GRAN'l"S the plaintiffs motion for summary judgment and DENIES the defendant’s cross-motion for summary judgment. BACKGROUND

I. Regulatory Landscape

Plaintiff Solenex seeks declaratory and injunctive relief for federal defendants’ alleged violations ofthe Administrative Procedure Act (“APA”), 5 U.S.C. § 55l et Sec/., by cancelling the Solenex lease after holding it in suspension for more than thirty years. Plaintiff raises several independent reasons for finding that federal defendants acted unlawfully: (l) federal defendants lack authority to cancel the lease both because the Secretary exceeded his authority and because his cancellation Was arbitrary and capricious, (2) the cancellation is time barred by a statutory limitations period or, alternatively, the doctrine of laches, (3) defendants are estopped from cancelling the lease by a pattern of conduct treating the lease as valid, and (4) the lease vvas properly issued in compliance With NEPA and the NHPA. A brief overview of these is in order.

First, plaintiff argues that the Department of lnterior’s (“Interior”) authority to administratively cancel a lease is limited under the l\/lineral Leasing Act of 1920 (“l\/lLA”). 30 U.S.C. §§ 181~287. The l\/lLA governs the Secretary of lnterior’s (hereinafter “the Secretary”) authority to issue leases for “[a]ll lands subject to disposition under this Act Which are known or believed to contain oil or gas deposits.” Ia’. § 226(a). Pursuant to the l\/ILA, the Secretary may also cancel those leases if the lease is (l) “in violation of the MLA, unless the current leaseholder is a bona fide purchaser,” z`a’. § l84(h)(l), (h)(2); (2) “When a lessee has violated the statute, regulations, or the lease itself, id. § lSS(_a); or (3)

“where the lessee is in violation of lease provisions after at least 30-days’ notice” and the lease is a non-producing lease, id. § lSS(b). lnterior has also promulgated its own regulations allowing for administrative cancellation of leases under certain conditions See 43 C.F.R. § 3 l08.5. Namely, that the Secretary can cancel leases for either (l) the lessee’s failure “to comply with any of the provisions of the law, the regulations issued thereunder, or the lease” after notice and 30 days to cure, 43 C.F.R. § 3108.3(a), or (2) the agency’s determination that the lease was “improperly issued.” [d. § 3l08.3(d).

As asserted by federal defendants, one of the ways in which a lease can be “improperly issued” and therefore subject to administrative cancellation is by non- compliance with either the National Environmental Policy Act (“NEPA”) or the National Historic Preservation Act (“NHPA”). Defs.’ l\/lot. at 27¢29. NEPA requires that agencies take a “hard look” at the environmental consequences, RO/)erlson v. Mel'/iow Valley Citl`ze)is Cou)ici'l, 490 U.S. 332, 350 (1989), of“major Federal actions” that “significantly affect [] the quality ofthe human environment.” 42 U.S.C. § 4332(C); 40 C.F.R. §§ l50.3, l501.4(c).l Nevertheless, an “agency is not constrained by NEPA from deciding that other values outweigh the environmental costs.” Robe)”tson, 490 U.S. at 350. NHPA, for its part,

requires that the agency “take into account the effect of [:an] undertaking on any historic

l As our Circuit has held, “NEPA's requirements vary based on the type of agency action in question ” Cz`ly OfP/ioenix, Arizona v. Huerta, 869 F.3d 963, 971 (D.C. Cir. 2017), Opz`m`on amended 011 reh’g, 881 F.3d 932 (D.C. Cir. 2018). lt is well settled that only “[a]ctions with significant environmental effects require a full environmental-impact statement” and that “[a]ctions with impacts that are not significant or are unknown require a briefer environmental assessment.” [a’. at 971-72.

property.” 54 U.S.C. §§ 300308, 306108. This requires that the agency consult with the Advisory Council of Historic Preservation (“ACHP”). See id. NHPA consultation is usually considered adequate where the acting agency has “visited the site [and] consulted with the preservation authorities” before concluding there will be no adverse impact on the historic property. Dimccm ’S Poz`nr LOI Owners Ass’n Inc. v. F.E.R.C., 522 F.3d 37l, 377 (D.C. Cir. 2008); Cf Nat’[ Pa)”ks C()nse/”vation Ass’)/z v. Um'ted Smles, l77 F. Supp. 3d l (D.D.C. 2016) (permitting mineral development in a designated NHPA historic district after the Forest Service conducted an environmental assessment but not a full-blown environmental impact statement). lmportantly, while both of these statutes require agencies to follow certain procedures to gather information to help assist with decision- making, they do not themselves impose substantive requirements with respect to the outcome of that decision-makingl See, e.g., Sierm Club v. Federal Energy Regulatory COmmz`Ssz`On, 867 F.3d l357, l367 (D.C. Cir. 2017) (“NEPA directs agencies only to look hard at the environmental effects of their decisions, and not to take one type of action or another.”) (internal quotation marks omitted); id. (“[NEPA] is primarily inforination- forcing”); Delaware Rl`ve/”keeper Network v. F.E.R.C., 753 F.3d l304, 1310 (D.C. Cir. 2014) (“NEPA is ‘essentially procedural’ and designed to ensure ‘fully informed and well- considered decision[s]’ by federal agencies) (_quoting VI. Ya)i/cee Nuclear Power Corp. vt NRDC, 435 U.S. 5l9, 558 (l978)); Nal ’le‘m'//ig Ass ’rz v. Fowler, 324 F.3d 752, 755 (D.C. Cir. 2003) (“An essentially procedural statute, [NHPA] imposes no substantive standards on agencies, but it does require them to solicit the Council’s comments and to take into account the effect of their undertakings.”) (internal citation omitted).

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Solenex LLC v. Zinke, Counsel Stack Legal Research, https://law.counselstack.com/opinion/solenex-llc-v-zinke-dcd-2018.