## Facts

- The Department of the Interior planned and noticed an offshore oil-and-gas lease sale (Lease Sale 53) for tracts on the Outer Continental Shelf (OCS) off California.
- California’s coastal zone, as relevant here, extended three miles seaward; the leased tracts were on the federally controlled OCS beyond state submerged lands.
- The California Coastal Commission asserted the lease sale would “directly affect” California’s coastal zone and demanded a CZMA § 307(c)(1) consistency determination before the sale.
- Interior modified the sale by removing some tracts but refused to provide a § 307(c)(1) consistency determination for the remaining tracts and proceeded toward the sale.
- California sued to enjoin sale of certain tracts, arguing that leasing begins a “chain of events” leading to exploration and development that would affect the coastal zone.
- The district court granted summary judgment for California, and the Ninth Circuit affirmed, holding § 307(c)(1) applied to the lease sale.

## Issues

1. Whether Interior’s sale of OCS oil-and-gas leases is a federal activity “directly affecting the coastal zone” requiring a CZMA § 307(c)(1) consistency determination.
2. Whether the possibility that leasing may lead to later exploration and development is sufficient to make the lease sale itself a “direct” effect on the coastal zone.

## Decision

- The Supreme Court reversed the Ninth Circuit.
- The Court held that an OCS lease sale is not an activity “directly affecting” the coastal zone within CZMA § 307(c)(1).
- Interior therefore was not required to conduct a § 307(c)(1) consistency determination before conducting the lease sale.

## Legal Principles

- CZMA § 307(c)(1) covers federal agency activities “directly affecting” the coastal zone; the term is construed in light of CZMA structure and legislative history.
- Section 307(c)(1) was aimed primarily at federal activities on federal lands physically near or within coastal areas but excluded from the CZMA’s formal definition of “coastal zone,” not OCS lease sales.
- Under OCSLA’s staged framework, a lease sale does not itself authorize exploration or development; later approvals govern the actions most likely to affect the coastal zone.
- Potential downstream effects from a lease sale, through an extended “chain of events,” are too attenuated to constitute a “direct” effect for § 307(c)(1).
- Reading § 307(c)(1) to reach OCS lease sales would create overlap with OCSLA’s processes and distort the federal–state allocation of authority over OCS resources.

## Conclusion

The Court ruled that CZMA § 307(c)(1) does not require a state consistency determination before the federal government sells OCS oil-and-gas leases, reserving state consistency review primarily for later, more immediate stages of offshore activity such as exploration and development approvals.


Secretary of the Dep’t of the Interior v. California, 464 U.S. 312 (1984)