Also known as:COA · cause of action · causes of action
Written by attorneys · grounded in primary & secondary sources — see below
An administrative requirement imposed by the Bureau of Land Management on an application for permit to drill. The requirement directs the lessee to adopt specified practices that avoid or reduce environmental impacts from drilling operations.
Sources & Authorities· 23 primary sources
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Cases
Statutes
How it applies
Common Examples
6
BLM Imposes COAs on APD
Cedar Creek Farms submits an APD to drill on federal land. The BLM reviews the proposal and determines that additional safeguards are needed to protect nearby wetlands. It therefore attaches COAs requiring the use of closed-loop drilling systems and regular water-quality monitoring before approving the permit.
Federal Question Involves COAs
Christopher Collins challenges a BLM decision that added COAs to his APD. He claims the conditions violate federal statutes governing mineral leasing. The court recognizes federal question jurisdiction because the complaint asserts rights arising directly under federal law.
Crestview Holdings receives an APD containing COAs that later prove unnecessary. The company establishes that the BLM acted arbitrarily but cannot prove actual financial loss. The court awards only nominal damages to vindicate the legal right.
Heartbalm Claim Involves COAs
Carlos Castillo promises to transfer mineral rights subject to future COAs. When the marriage plans collapse, the recipient seeks recovery of expenses incurred in reliance on the promise. The court treats the claim as a quasi-contract action limited to actual outlays.
Tag Jurisdiction Over COA Challenge
Cody Callahan is served with process while briefly present in the forum state. He faces a suit alleging that COAs attached to his APD exceed BLM authority. The court exercises personal jurisdiction based on his physical presence at the time of service.
Diversity Jurisdiction and COAs
Cassandra Cooper files a diversity action contesting COAs imposed on her federal lease. She changes domicile after filing. The court retains jurisdiction because diversity existed when the suit was instituted.
Common questions
Frequently Asked
2
What do COAs require of a drilling operator?+
COAs direct the operator to adopt specific practices that avoid or reduce environmental impacts from drilling. They are attached when the BLM issues an APD and are enforced through periodic inspections.
Supporting sources
How are COAs enforced after an APD is approved?+
The BLM inspects the well site to verify compliance with the COAs and other permit conditions. Failure to follow the COAs can result in enforcement actions.
Supporting sources
529 U.S. 598 (2000)Constitutional Law
…offers a federal civil rights remedy aimed exactly at violence against women, as an alternative to the generic state tort causes of action found to be poor tools of action by the state task forces. See S. Rep. No. 101-545, at 45 (noting difficulty of fitting gender-motivated crimes into common-law categories). As the 1993…