Shell Oil Co. v. Department of Energy

OPINION OF THE COURT

Eight energy producing companies brought this action to challenge the annual financial reporting requirement (Form EIA-28) promulgated by the Administrator of the Energy Information Administration (EIA) of the Department of Energy (DOE). The district court, on cross motions for summary judgment filed by the parties after discovery, entered summary judgment for the defendants, and the companies appeal.

In essence, the companies attack EIA’s implementation of the Federal Reporting System (FRS) on two grounds. First, they claim that EIA has no authority to require them to…