## Facts

- Congress enacted the Surface Mining Control and Reclamation Act of 1977 (SMCRA), creating national minimum standards for surface coal mining and a state-implemented program subject to federal approval and oversight.
- The Secretary of the Interior, through the Office of Surface Mining Reclamation and Enforcement, issued comprehensive regulations governing permit content, performance standards, and criteria for approval of state regulatory programs.
- The regulations required operators to submit permit-application information and comply with technical standards that were more detailed than the items expressly listed in SMCRA.
- Coal-industry petitioners and other regulated parties challenged numerous provisions, asserting the regulations exceeded statutory authority, improperly constrained state discretion under SMCRA’s federal–state structure, and were arbitrary and capricious under the Administrative Procedure Act (APA).
- The district court upheld most of the regulations.
- Petitioners appealed, contesting the legality of multiple discrete regulatory provisions and the Secretary’s overall authority to prescribe detailed requirements affecting state programs and mine operations.

## Issues

1. Whether SMCRA authorizes the Secretary to require permit information and impose detailed performance standards beyond those expressly enumerated in the statute.
2. Whether the challenged regulations impermissibly displaced state discretion within SMCRA’s cooperative federalism scheme by effectively converting state administration into direct federal control.
3. Whether particular regulatory provisions were inconsistent with SMCRA or invalid under the APA because they conflicted with statutory text or lacked a reasoned explanation.

## Decision

- The D.C. Circuit largely affirmed the district court and upheld most of the regulations.
- The court concluded SMCRA delegates broad rulemaking authority to the Secretary to issue regulations necessary to carry out the Act’s purposes, including specifying minimum permit-information requirements and detailed operational standards.
- The court rejected the argument that SMCRA sharply limits federal oversight of state programs; the Secretary may require detailed standards as conditions for state program approval, consistent with national minimum requirements.
- The court vacated or remanded a limited set of specific provisions that conflicted with statutory requirements or were insufficiently supported by the agency’s rationale and record.

## Legal Principles

- When a statute grants an agency authority to issue regulations necessary to carry out statutory purposes, the agency may “fill in the details” with requirements not exhaustively enumerated, so long as they reasonably relate to statutory objectives and do not contradict explicit statutory commands.
- Under SMCRA’s cooperative federalism design, states may obtain primary regulatory authority, but the Secretary retains authority to prescribe national minimum standards and to condition state program approval on compliance with federal regulations.
- Courts generally defer to an agency’s technical judgments in complex regulatory fields if the agency considers relevant factors and provides a rational explanation connecting the record to the regulatory choices.
- Regulations are invalid to the extent they alter statutory schemes, create unauthorized exceptions, or otherwise lack a sufficient statutory basis or reasoned justification under APA review.

## Conclusion

The court sustained the core federal surface-mining regulatory framework under SMCRA, holding that Interior could impose detailed permit and performance requirements to implement national standards and evaluate state programs, while setting aside or remanding discrete rules that exceeded statutory limits or lacked adequate justification.


In re Permanent Surface Mining Regulation Litigation, 653 F.2d 514 (D.C. Cir. 1981)