San Juan Citizens Alliance v. DOI, No. 13-02466, 2014 WL 4854976 (D. Colo. Sept. 29, 2014) (Blackburn, J.)
Re: Request for "expressions of interest" submitted to Bureau of Land Management (BLM) as part of agency sale of oil and gas leases
Disposition: Approving and adopting Recommendation of Magistrate Judge; denying third party Motion to Intervene
- Exemption 4: The court "concur[s] with the analysis of the magistrate judge." The magistrate judge describes "Western Energy Alliance [WEA] [as] a non-profit trade association representing over 400 companies engaged in exploration and production of oil and natural gas." The magistrate judge also notes that WEA members "routinely submit EOIs." The court notes that "[u]nder Exemption 4 of the FOIA, the BLM redacted [one] e-mail address" and "[t]hat e-mail address is the only information at issue in this case." The court relates that "WEA argues that this case, as a practical matter, will impair the ability of members of the alliance to protect their interests." "The magistrate judge recommends that the motion to intervene be denied because resolution of this case, on a very focused issue, will not impair or impede the ability of alliance members to protect their interests." "Addressing permissive intervention, the magistrate judge concludes that WEA does not have a claim which shares a common question of law or fact with the claims of the plaintiff in this action."