Healthy Gulf v. United States Department of the Interior

The Outer Continental Shelf Lands Act (OCSLA) gave the Department of the Interior (Interior) (defendant) authority to lease portions of the Outer Continental Shelf (OSC) to energy companies for offshore oil-and-gas development. OCSLA imposed a four-stage framework. Those four stages were program, leasing, exploration, and development, with each stage becoming narrower in scope. The program stage required the Interior to prepare a five-year program of proposed leases, specifying as precisely as possible the size, timing, and location of leasing activity that the secretary believed would best meet the nation’s energy needs. The Interior’s 2024–2029 program authorized up to three lease sales in the Gulf of Mexico (GOM) region, scheduled for 2025, 2027, and 2029. Healthy Gulf (plaintiff), a coalition of organizations seeking to protect the GOM and its communities, filed suit to challenge the program. Healthy Gulf alleged that the Interior violated OCSLA when adopting the program because, among other things, the Interior (1) did not appraise the vulnerability of each GOM community individually to determine how it would respond to harms from drilling and (2) failed to consider how the program’s leasing would interfere with other present or anticipated uses of the GOM. In response, the Interior argued that (1) it was not required to assess the vulnerability of each community individually and (2) it sufficiently considered risks to other present or intended uses of the GOM. The court considered the parties’ arguments.