Wyoming v. United States Department of the Interior

493 F. Supp. 3d 1046 (2020)

From our private database of 45,900+ case briefs, written and edited by humans—never with AI.

Wyoming v. United States Department of the Interior

United States District Court for the District of Wyoming
493 F. Supp. 3d 1046 (2020)

Facts

Associated natural gas is gas produced during an oil well’s normal production. Associated natural gas that could not be easily captured was typically disposed of by venting (i.e., releasing the gas into the atmosphere) or flaring (i.e., burning the gas). Venting and flaring both waste the same amount of gas. However, because methane is a potent greenhouse gas, venting methane into the atmosphere raised significant global-climate-change concerns. By contrast, flaring the methane turns the gas into nitrogen oxides that primarily impacts only local air pollution. The United States Secretary of the Interior (defendant), through the federal Bureau of Land Management (BLM), had the statutory authority under the Mineral Leasing Act (MLA) to prevent undue waste of federal and Indian mineral resources. Accordingly, the BLM regulated venting and flaring with respect to oil-and-gas leases covering federal and Indian lands. In 2017, the BLM promulgated a rule that, among other things, (1) prohibited venting except in limited situations, (2) set a volume of allowable flared gas and required operators to capture a certain percentage of associated natural gas produced per month, and (3) imposed inspection and repair requirements on operators to combat gas leaks. The BLM’s rule went further than some existing Environmental Protection Agency (EPA) air-quality regulations and also required states, localities, and tribes to seek variances from the BLM if any EPA-approved standards for those entities conflicted with the BLM’s rule. The BLM considered the rule’s costs to include engineering costs related to updating and repairing equipment but concluded that those costs were outweighed by benefits including cost savings from the recovery and sale of the associated natural gas and the environmental benefits of reducing global methane emissions. The State of Wyoming (plaintiff) petitioned for review of the BLM’s rule, arguing that the BLM was using the rule to regulate oil-and-gas-related air pollution, which was a matter reserved solely for the EPA under the Clean Air Act (CAA), and that the rule exceeded the scope of the BLM’s authority under the MLA.

Rule of Law

Issue

Holding and Reasoning (Skavdahl, J.)

What to do next…

  1. Unlock this case brief with a free (no-commitment) trial membership of Quimbee.

    You’ll be in good company: Quimbee is one of the most widely used and trusted sites for law students, serving more than 736,000 law students since 2011. Some law schools—such as Yale, Berkeley, and Northwestern—even subscribe directly to Quimbee for all their law students.

    Unlock this case briefRead our student testimonials
  2. Learn more about Quimbee’s unique (and proven) approach to achieving great grades at law school.

    Quimbee is a company hell-bent on one thing: helping you get an “A” in every course you take in law school, so you can graduate at the top of your class and get a high-paying law job. We’re not just a study aid for law students; we’re the study aid for law students.

    Learn about our approachRead more about Quimbee

Here's why 736,000 law students have relied on our case briefs:

  • Written by law professors and practitioners, not other law students. 45,900 briefs, keyed to 984 casebooks. Top-notch customer support.
  • The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
  • Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
  • Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.

Access this case brief for FREE

With a 7-day free trial membership
Here's why 736,000 law students have relied on our case briefs:
  • Reliable - written by law professors and practitioners, not other law students
  • The right length and amount of information - includes the facts, issue, rule of law, holding and reasoning, and any concurrences and dissents
  • Access in your class - works on your mobile and tablet
  • 45,900 briefs - keyed to 984 casebooks
  • Uniform format for every case brief
  • Written in plain English - not in legalese and not just repeating the court's language
  • Massive library of related video lessons - and practice questions
  • Top-notch customer support

Access this case brief for FREE

With a 7-day free trial membership