American Petroleum Institute v. Department of the Interior

The D.C. Circuit Court of Appeals denied environmental groups’ petition for review challenging the 2024–2029 National Outer Continental Shelf Oil and Gas Leasing Program, which authorized up to three lease sales in the Gulf of Mexico region. As an initial matter, the court found that the groups had associational standing to bring the suit on behalf of their members. On the merits, the court found that the U.S. Department of the Interior satisfied obligations under the Outer Continental Shelf Lands Act (OCSLA) to, among other things, evaluate how offshore leasing risks affect vulnerable communities, analyze environmental sensitivity, and consider potential interference with other present or future uses of the Gulf of Mexico region. The D.C. Circuit further found that the Interior Department’s balancing of the relevant environmental and economic factors satisfied OCSLA requirements.

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On April 30, 2025, the D.C. Circuit Court of Appeals granted American Petroleum Institute’s (API) motion for voluntary dismissal of its petition for review challenging the 2024-2029 National Outer Continental Shelf Oil and Gas Leasing Program approved by the Biden administration in 2023. API had asked the court to remand the program for the U.S. Department of the Interior to consider whether to schedule more than the three sales over five years that were included in the program. In its motion for voluntary dismissal, API said it was “heartened” by the Interior Department’s announcement on April 18, 2025 that it would develop a new offshore oil and gas leasing program to replace the Biden program. The Interior Department consented to API’s motion, providing a statement in which it said that “[d]eveloping a new schedule for oil and gas leasing on the Outer Continental Shelf is of the highest priority for Interior.” Environmental organizations’ challenge to the Biden administration’s program is still pending and was argued on May 6.

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