Mealey's (July 22, 2015, 1:55 PM EDT) -- SAN FRANCISCO — A panel of the Ninth Circuit U.S. Court of Appeals on July 20 held that a district court incorrectly treated an environmental organization’s claims challenging the Bureau of Land Management (BLM)’s decision to extend 26 geothermal leases as arising only under Section 1005(a) of the Geothermal Steam Act when the organization’s claims fell under both Sections 1005(a) and 1005(g) of the act because the BLM must conduct environmental, historical and culture reviews before deciding whether to grant lease extensions (Pit River Tribe, et al. v. Bureau of Land Management, et al., No. 13-16961, 9th Cir.; 2015 U.S. App. LEXIS 12480)....