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Keywords

plaintiffmotionsummary judgmentcompliancerescissionmotion for summary judgment

lawsuitplaintiffmotionsummary judgmentrescissionmotion for summary judgment

Related Cases

California v. Bernhardt, 472 F.Supp.3d 573

Facts

The case arose from BLM's 2018 rescission of the 2016 Waste Prevention Rule, which aimed to minimize waste of oil and gas during production. The plaintiffs, including California and New Mexico, argued that BLM's new definition of 'waste' and the rescission process violated the Mineral Leasing Act and the Administrative Procedure Act. The court noted that BLM had previously established the 2016 Rule after extensive public input and that the rescission process lacked similar engagement and justification.

BLM's efforts to enact, then to modify, suspend, and ultimately repeal the 2016 Rule have been the subject of numerous lawsuits.

Issue

Did the Bureau of Land Management's (BLM) rescission of the 2016 Waste Prevention Rule violate the Mineral Leasing Act and the Administrative Procedure Act by being arbitrary and capricious?

Rule

The court applied the principles of the Mineral Leasing Act, which mandates BLM to prevent waste of oil and gas, and the Administrative Procedure Act, which requires agencies to act rationally and provide a meaningful opportunity for public participation in rulemaking.

The Administrative Procedure Act (“APA”) imposes limits on these agencies’ actions, prohibiting actions found to be “arbitrary, capricious, an abuse of discretion, or otherwise not in accordance with law.”

Analysis

The court found that BLM's new definition of 'waste' was not a reasonable interpretation of the Mineral Leasing Act, as it allowed for waste when compliance costs exceeded the value of the resources. Additionally, BLM failed to justify its reversal of the previous rule and did not adequately consider the environmental impacts of the rescission, violating the requirements of the Administrative Procedure Act.

In its haste, BLM ignored its statutory mandate under the Mineral Leasing Act, repeatedly failed to justify numerous reversals in policy positions previously taken, and failed to consider scientific findings and institutions relied upon by both prior Republican and Democratic administrations.

Conclusion

The court granted the plaintiffs' motion for summary judgment, vacating the rescission of the 2016 Waste Prevention Rule and staying the vacatur for 90 days to allow for compliance.

Plaintiffs' motion for summary judgment granted; rule rescission vacated, with such vacatur stayed for 90 days.

Who won?

Plaintiffs (California and New Mexico) prevailed because the court found that BLM's actions were arbitrary and capricious, failing to adhere to statutory mandates and procedural requirements.

The Court details herein the myriad inadequacies upon which the Rescission is based.

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