## Facts

- The Secretary of the Interior adopted the first nationwide five-year offshore oil and gas leasing program required by the 1978 amendments to the Outer Continental Shelf Lands Act (OCSLA).
- The program scheduled lease sales by size, timing, and location and emphasized early, extensive leasing to increase domestic production, including expanded leasing in frontier regions (e.g., Alaska and the Atlantic).
- The State of California (through the Governor and state agencies), the State of Alaska, environmental organizations, and the North Slope Borough and related petitioners filed consolidated petitions for review in the D.C. Circuit under OCSLA.
- Petitioners argued the program insufficiently considered OCSLA § 18 factors, including environmental sensitivity, risks to marine/coastal/human environments, impacts on coastal communities, and affected states’ policies.
- Petitioners also contended the program failed OCSLA’s requirements for “best information available” and for “equitable sharing of developmental benefits and environmental risks” among regions, given concentrated leasing-related risks in certain areas.
- The Secretary and industry intervenors argued that § 18 did not require a formal quantitative cost-benefit method at the program stage and that the program used the best reasonably obtainable information, with further environmental analysis at later stages.

## Issues

1. Whether the five-year leasing program complied with OCSLA § 18’s substantive and procedural requirements, including consideration of specified factors and the regional “equitable sharing” requirement.
2. Whether the Secretary satisfied OCSLA’s “best information available” standard despite acknowledged data gaps and uncertainty.
3. Under APA arbitrary-and-capricious review, what level of explanation and record support is required for a nationwide, programmatic leasing schedule.

## Decision

- The court denied the petitions in part and granted them in part.
- It upheld the overall authority to adopt a nationwide, programmatic five-year leasing plan and rejected challenges that would have invalidated the program in full.
- It remanded to the Secretary for further consideration and explanation on specific statutory deficiencies, including regional allocations and the basis for concluding that risks and benefits were equitably shared.
- The court did not vacate the entire program.

## Legal Principles

- Under APA arbitrary-and-capricious review, a court examines whether the agency considered relevant factors and articulated a rational connection between the facts found and the choices made, without substituting judicial judgment for technical agency judgments.
- OCSLA § 18 requires reasoned balancing of energy-development goals against environmental and coastal-community protection, using the best information available; it does not require a rigid quantitative or mathematical cost-benefit formula.
- “Best information available” does not demand complete or error-free data; it requires a good-faith effort to obtain and evaluate reasonably obtainable, current, relevant information, and to explain how uncertainty is accounted for in program design.
- The OCSLA equitable-sharing mandate requires more than conclusory statements; the agency must provide a reasoned comparison of regional developmental benefits and environmental risks, supported by the best available information.
- Programmatic planning may defer some detail to later, site-specific stages, but the threshold program must still satisfy OCSLA’s balancing and explanation requirements and must not rest on unsupported assumptions about key statutory factors.

## Conclusion

The D.C. Circuit upheld the general structure of Interior’s first OCSLA five-year leasing program but remanded for a fuller, reasoned explanation—grounded in the best available information—of how the program addressed uncertainty, state and community concerns, and especially whether the regional distribution of developmental benefits and environmental risks was “equitable” as OCSLA requires.


California v. Watt, 668 F.2d 1290 (D.C. Cir. 1981)