culminated in 1916 when Congress enacted the SRHA, (48) which reserved
statutes containing mineral reservations, the SRHA reservation did not
the SRHA bill, stated that "[a]ll mineral[s] within the lands are
The SRHA was responsible for the distribution of over 70 million
the capacious nature of the SRHA mineral reservation, (61) the
interpreted the SRHA mineral reservation on a number of occasions.
falls within the purview of the SRHA mineral reservation.
on lands patented under the SRHA is a mineral reserved to the United
reservation of the SRHA includes geothermal resources, particularly
power when it enacted the SRHA in 1916 and therefore could not have
interpreting the SRHA reservation to encompass geothermal resources.
Notably, the Ninth Circuit in Union Oil considered the SRHA mineral