Public Lands: Outer Continental Shelf Lands Act; Unitization Administrative Law: Scope of Judicial Review

摘要

In June 1986, the MMS approves the formation of the Santa Maria Unit consisting of eight OCS leases. Prior to the formation of the SMU, Aera Energy drills four exploratory wells, all of which are not capable of producing in paying quantities. Nonetheless, the MMS concludes that the eight OCS leases, including leases upon which the four wells were drilled should be unitized. Shortly thereafter, Aera drills a producing well on one of the eight leases. From 1986 through June 1994 the MMS approves a series of requests to suspend operations in the SMU. A separate suspension is issued that runs through 1999. During the 1986-1999 period Aera drills no additional wells. In 1999, the MMS decides that three of the leases committed to the SMU should no longer be in the SMU and therefore should not be entitled to suspensions of operation.