Blm
Pit River Tribe v. Bureau of Land Management
Opinion
Opinion
Christen, J.
The Pit River Tribe and several regional environmental organizations (collectively Pit River) appeal from the district court’s order granting judgment on the pleadings on Pit River’s action challenging the Bureau of Land Management’s (BLM) continuation of 26 geothermal leases in northeastern California’s Medicine Lake Highlands. .Pit River’s complaint alleged that BLM’s decision violated the Geothermal Steam Act, the National Environmental Policy Act (NEPA), the National Historic Preservation Act (NHPA), and the government’s fiduciary trust obligation to Indian tribes. The district court concluded Pit River lacked prudential standing to bring its Geothermal Steam Act claims because the claims did not fall within the zone of interests of the Act’s lease-continuation provision, 30 U.S.C. § 1005 (a). The district court rejected Pit River’s other claims on the basis that BLM had no discretion to consider environmental, historical, or cultural interests before continuing the leases under § 1005(a).
We conclude that the district court incorrectly treated Pit River’s claims as arising under only § 1005(a) of the Geothermal Steam Act. BLM’s 1998 decision to continue the 26…