Citizens for Clean Air v. TRAN
CourtCourt of Appeals for the Fifth Circuit
Date FiledAugust 12, 2026
Docket25-60202
StatusPublished
📰 News Coverage: Read the LAWS.com news report on this case
Full Opinion
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United States Court of Appeals
for the Fifth Circuit United States Court of Appeals
Fifth Circuit
____________ FILED
August 12, 2026
No. 25-60202
Lyle W. Cayce
____________
Clerk
Citizens for Clean Air & Clean Water in Brazoria
County,
Petitioner,
versus
United States Department of Transportation; Sean
Duffy, Secretary, U.S. Department of Transportation, in his official capacity
as Secretary of the U.S. Department of Transportation; United States
Maritime Administration, an agency of the U.S. Department of
Transportation; Administrator, in his official capacity as Administrator
of the U.S. Maritime Administration; United States
Coast Guard, an agency of the U.S. Department of Homeland Security;
Kevin E. Lunday, in his official capacity as Commandant of the U.S.
Coast Guard,
Respondents.
______________________________
Petition for Review of an Order of the Maritime Administration
Agency No. MARAD-2019-0093
______________________________
Before Clement, Southwick, and Engelhardt, Circuit Judges.
Edith Brown Clement, Circuit Judge:
The Deepwater Port Act of 1974 (“DWPA”) comprehensively
regulates the construction and operation of deepwater ports. To construct a
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deepwater port, a person must first apply for a license from the Secretary of
Transportation. 33 U.S.C. § 1503(a). When the Secretary receives an
application, he must publish a notice describing “an application area
encompassing the deepwater port site proposed by such application.” Id.
§ 1504(d)(1). The DWPA requires that there be only one deepwater port per
application area, so if the Secretary receives more than one application for
the same application area, he must issue a license to the port that “clearly
best serves the national interest.” Id. § 1504(i).
In 2025, the Secretary approved Intervenor Texas GulfLink, LLC’s
application to construct a deepwater port, even though its proposed pipeline
would intersect with another deepwater port’s pipeline. Petitioner Citizens
for Clean Air & Clean Water in Brazoria County (“Better Brazoria”)
challenges that decision. It argues, in relevant part, that the DWPA requires
the Secretary to include a deepwater port’s proposed pipeline in its
application area, and if Texas GulfLink’s application area had been properly
designated, it would include two deepwater ports.
Thus, we must decide whether the DWPA requires the Secretary to
include a deepwater port’s proposed pipeline in its application area. We hold
that it does: The DWPA requires the Secretary to designate “an application
area encompassing the deepwater port site,” id. § 1504(d)(1), and it
expressly defines “deepwater port” to “include[] all components and
equipment, including pipelines . . . to the extent they are located seaward of
the high water mark,” id. § 1502(9)(B). Texas GulfLink’s application area,
properly drawn, would intersect with another deepwater port’s pipeline,
violating the DWPA’s requirement that there be only one deepwater port
per application area. Accordingly, we grant the petition for review, vacate the
record of decision (“ROD”) approving Texas GulfLink’s application, and
remand for further proceedings.
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I
A
In 1973, to retaliate against the United States for supporting Israel in
the 1973 Arab–Israeli War, Arab members of the Organization of Petroleum
Exporting Countries (“OPEC”) embargoed the export of oil to the United
States. Oil Embargo, 1973–1974, U.S. Dep’t of State, Off. of the
Historian, https://history.state.gov/milestones/1969-1976/oil-embargo
[https://perma.cc/X8GM-4NQ4] (last visited June 29, 2026). This embargo
ignited economic and energy crises that triggered several congressional
responses, including the passage of the DWPA. See S. Rep. No. 93-1217, at
6 (1974) (citing the “Arab oil embargo” as an impetus for enacting the
legislation, given the “high priority to reduce American reliance on foreign
petroleum supplies and attain domestic energy self-sufficiency”), as reprinted
in 1974 U.S.C.C.A.N. 7529, 7534.
Congress enacted the DWPA, in part, “to authorize and regulate the
location, ownership, construction, and operation of deepwater ports in
waters beyond the territorial limits of the United States.” 33 U.S.C.
§ 1501(a)(1). Moreover, Congress sought “to promote the construction and
operation of deepwater ports as a safe and effective means of importing oil or
natural gas into the United States and transporting oil or natural gas from the
outer Continental Shelf while minimizing tanker traffic and the risks
associated with that traffic.” Id. § 1501(a)(5).
Deepwater ports are not used for the exploration or production of oil
or natural gas; instead, they serve only as import or export terminals. The
DWPA defines a “deepwater port” as a “fixed or floating manmade
structure . . . or any group of such structures” that is “located beyond State
seaward boundaries” and is “used or intended for use as a port or terminal
for the transportation, storage, or further handling of oil or natural gas for
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transportation to or from any State.” Id. § 1502(9)(A). The statute’s
definition of “deepwater port” expressly “includes all components and
equipment, including pipelines, pumping stations, service platforms, buoys,
mooring lines, and similar facilities to the extent they are located seaward of
the high water mark.” Id. § 1502(9)(B).
Under the DWPA, no person may own, construct, or operate a
deepwater port without a license issued by the Secretary of Transportation,
id. § 1503(a), who has delegated the authority to process DWPA applications
and issue licenses to the U.S. Maritime Administration (“MARAD”) and
the U.S. Coast Guard, 33 C.F.R. § 148.3(a)–(b); 49 C.F.R. § 1.93(h). After
receiving an application to construct a deepwater port and confirming that
the application is complete, the Secretary must “publish in the Federal
Register a notice of the application” and “a summary of the plans.” 33
U.S.C. § 1504(c)(1)(B)(ii)(I). That notice must include “a description . . . of
an application area encompassing the deepwater port site proposed by such
application and within which construction of the proposed deepwater port
would eliminate, at the time such application was submitted, the need for any
other deepwater port within that application area.” Id. § 1504(d)(1). The
DWPA defines “application area” as “any reasonable geographical area
within which a deepwater port may be constructed and operated.” Id.
§ 1504(d)(2). “Such application area shall not exceed a circular zone, the
center of which is the principal point of loading and unloading at the port,
and the radius of which is the distance from such point to the high water mark
of the nearest adjacent coastal State.” Id.
Because there may only be one deepwater port per application area,
the DWPA requires the Secretary to “call for submission of any other
applications for licenses for the ownership, construction, and operation of a
deepwater port within the designated application area.” Id. § 1504(d)(3). If
more than one application is submitted for an application area, the Secretary
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must issue a license to the deepwater port that “clearly best serves the
national interest,” as determined by a list of four factors. Id. § 1504(i)(2)–(3).
If no proposal “clearly best serves the national interest,” the statute provides
an “order of priorities” for issuing a license. Id. § 1504(i)(2).
B
In addition to passing the DWPA, Congress responded to OPEC’s
oil embargo by enacting the Energy Policy and Conservation Act of 1975,
which effectively banned the export of domestic crude oil from the United
States. Pub. L. No. 94-163 § 103, 89 Stat. 871, 877–78 (repealed 2015). This
export ban was in place for forty years until Congress—motivated by the
surplus of domestic crude oil produced by the shale oil boom—lifted the ban
in 2015. See Consolidated Appropriations Act of 2016, Pub. L. No. 114-113,
§ 101(a), 129 Stat. 2242, 2987 (2015).
The lifting of the export ban heightened interest in the efficient export
of domestic oil. The most efficient way to export oil is by using the largest
available crude carrier ships, which are often Very Large Crude Carriers
(“VLCCs”). These ships are so large and carry so much oil (up to two
million barrels) that they must be loaded in deep water. There are two ways
to load these ships. The first is by a process called “reverse lightering,” in
which the VLCC remains offshore in deep water and smaller tankers take
trips back and forth from an onshore port to deliver oil to the VLCC. The
other method is to pipe oil to an offshore deepwater port from which the
VLCC can load directly. Because reverse lightering increases loading time,
vessel traffic, and expenses, oil companies prefer to load VLCCs from a
deepwater port.
Currently, there is only one crude oil deepwater port in the United
States: the Louisiana Offshore Oil Port (“LOOP”). But in 2019, MARAD
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received three applications to build deepwater ports off the coast of Freeport,
Texas.
MARAD published notices of two applications in March 2019: one
to construct the Sea Port Oil Terminal (“SPOT”), and the other to
construct the Texas Crude Offshore Loading Terminal (“Texas COLT”).
MARAD’s notice described SPOT’s application area as “a circle having a
radius of no less than three-and-three-tenths (3.30) nautical miles centered
at SPOT’s proposed platform . . . and 0.25 nautical miles on either side of
SPOT’s proposed pipeline route between the terminal and the shore.”
Deepwater Port License Application: SPOT Terminal Services LLC
(SPOT), 84 Fed. Reg. 7413, 7414 (Mar. 4, 2019). Texas COLT’s
application area was almost identical, only its radius was “no less than three
and one-half (3.50) nautical miles.” Deepwater Port License Application:
Texas COLT LLC (Texas COLT), 84 Fed. Reg. 7968, 7969 (Mar. 5, 2019).
Pursuant to 33 U.S.C. § 1504(d)(3), both notices called for “[a]ny person
interested in applying for the ownership, construction, and operation of a
deepwater port within this designated application area” to file a notice of
intent to apply within sixty days and a completed application within ninety
days. 84 Fed. Reg. at 7414, 7969.
Within the sixty-day deadline, Texas GulfLink notified MARAD that
it intended to apply to construct a deepwater port. Texas GulfLink sent its
letter of intent “[o]ut of an abundance of caution” because it knew that its
proposed pipeline would cross both SPOT’s and Texas COLT’s pipelines
and, consequently, their application areas. On May 30, 2019, Texas GulfLink
filed its application with MARAD.
When MARAD published its notice of Texas GulfLink’s application,
it described its application area differently than it had described SPOT’s and
Texas COLT’s. The notice designated an application area “that is a circle
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having a radius of no less than three and one-half (3.50) nautical miles
centered at Texas GulfLink’s proposed platform.” Deepwater Port License
Application: Texas GulfLink LLC (Texas GulfLink), 84 Fed. Reg. 30298,
30299 (June 26, 2019). Unlike SPOT’s and Texas COLT’s application
areas, Texas GulfLink’s did not include “0.25 nautical miles on either side
of [the] proposed pipeline route between the terminal and the shore.” See 84
Fed. Reg. at 7414, 7969. MARAD’s notice acknowledged that the agency
“had initially included pipelines within the application areas of recent
projects,” but after reviewing the DWPA’s text and legislative history, it
“determined that for the purpose of establishing application areas, Congress
focused on the circular area surrounding a deepwater port’s principal point
of loading and unloading.” 84 Fed. Reg. at 30299. Thus, in MARAD’s view,
it was “consistent with Congressional intent” to exclude Texas GulfLink’s
proposed pipeline from its application area. Id. The notice further indicated
that MARAD would retroactively adjust the application areas for SPOT
and Texas COLT accordingly. Id.
After receiving the three applications, MARAD conducted several
rounds of environmental review for the proposed deepwater ports, as
required by the DWPA and the National Environmental Policy Act
(“NEPA”). See 33 U.S.C. § 1504(f)(2) (designating MARAD the lead
agency for all DWPA applications for purposes of NEPA). Texas COLT
ultimately withdrew its application, leaving only SPOT’s and Texas
GulfLink’s applications for MARAD to review.
MARAD approved SPOT’s application in November 2022. Better
Brazoria filed a petition for review of that licensing decision, arguing that the
environmental impact statement for that project violated both NEPA’s and
the DWPA’s requirements. We denied the petition for review, holding that
MARAD violated neither statute in approving SPOT’s application.
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Citizens for Clean Air & Clean Water in Brazoria Cnty. v. U.S. Dep’t of
Transp., 98 F.4th 178, 198 (5th Cir. 2024).
Then, on February 14, 2025, MARAD approved Texas GulfLink’s
application. Better Brazoria timely filed the instant petition for review of that
decision under the DWPA’s citizen-suit provision, 33 U.S.C. § 1516.
Better Brazoria argues that the ROD approving Texas GulfLink’s
application must be vacated for two reasons. First, the group contends that
MARAD violated the DWPA by excluding Texas GulfLink’s proposed
pipeline from its application area. Because a properly drawn application area
would intersect with SPOT’s pipeline, Better Brazoria argues that
MARAD violated the DWPA by approving two deepwater ports within the
same application area. Second, Better Brazoria asserts that MARAD’s
decision to designate Texas GulfLink’s application area differently than it
had designated SPOT’s and Texas COLT’s was arbitrary and capricious
because the agency did not offer a sufficiently reasoned explanation for its
change of course. We need only address the first issue to resolve this appeal.
II
Before reaching the merits of Better Brazoria’s challenge, even though
no party challenges Better Brazoria’s Article III standing, we must satisfy our
continuing obligation to assure ourselves of our jurisdiction. Green Valley
Special Util. Dist. v. City of Schertz, 969 F.3d 460, 468 (5th Cir. 2020) (en
banc). Better Brazoria has associational standing on behalf of its members if
“(1) the association’s members would independently meet the Article III
standing requirements; (2) the interests the association seeks to protect are
germane to the purpose of the organization; and (3) neither the claim asserted
nor the relief requested requires participation of individual members.” Tex.
Democratic Party v. Benkiser, 459 F.3d 582, 587 (5th Cir. 2006) (citing Hunt
v. Wash. State Apple Advert. Comm’n, 432 U.S. 333, 343 (1977)). To
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demonstrate that at least one of its members has standing, Better Brazoria
must show “(1) an injury in fact; (2) that is traceable to the defendant’s
challenged conduct; and (3) that is likely to be redressed by a favorable
decision.” Id. at 586 (citing Lujan v. Defs. of Wildlife, 504 U.S. 555, 560–61
(1992)).
We recently held that challengers to another proposed deepwater port
in the Gulf of America failed to satisfy this standard. In Center for Biological
Diversity v. United States Department of Transportation, 180 F.4th 796, 800–
01 (5th Cir. 2026), three environmental organizations challenged
MARAD’s approval of Delfin LNG’s application to construct a deepwater
port off the coast of Texas and Louisiana. But none of these groups identified
a single member “who fishes near the port, boats beside it, works around it,
or otherwise uses Project-affected waters or nearby areas in a way the Project
would impair.” Id. at 801. The groups’ members asserted general “health,
recreational, business, professional and scientific interests” that would be
threatened by the construction of the deepwater port, but they did not show
that they planned to make use of specific areas that would be affected by the
project. Id. at 803–06. For instance, one declarant “refer[red] vaguely to his
‘community’ and ‘area’ without relating either to the Project’s location or
scope.” Id. at 804. Because none of the organizations showed that their
members would suffer “a concrete, particularized injury fairly traceable to
the challenged license,” they lacked standing to challenge the license, and we
denied their petition for review. Id. at 806.
But we have also held that another group of petitioners—including
Better Brazoria—did have standing to challenge a proposed deepwater port.
In Citizens for Clean Air, the petitioners relied in part on a declaration from
Pamela Harris, who owned a home one mile from SPOT’s proposed
pipeline. 98 F.4th at 188. Harris voiced concern that the pipeline would
“carry increased risks of oil spills, unwanted noise, habitat destruction, and
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property devaluation.” Id. She also said that the pipeline’s construction and
operation “would create an aesthetic and physical nuisance, negatively
affecting her enjoyment of her property” and “her recreational activities” on
the nearby beach. Id. We held that Harris’s declaration showed that an
individual member would have standing because “she ‘plan[ned] to make use
of the specific sites’ where the environmental effects from SPOT would
allegedly be felt” and therefore “identified cognizable interests threatened
by the project.” Id. (quoting Summers v. Earth Island Inst., 555 U.S. 488, 499
(2009)).
Here, Better Brazoria’s members have identified cognizable interests
very similar to those we found sufficient to establish standing in Citizens for
Clean Air. One member, AJ Jinkins, owns a home about a mile and a half from
Texas GulfLink’s proposed tank farm and close to its proposed pipeline. In
his sworn declaration, Jinkins expresses concern that the tank farm would
increase the risk of flooding, particularly in the event of a hurricane, and that
the flooding would pollute his well water. He says that he values “the peace
and quiet of living in the country,” but the light and noise pollution from the
tank farm would make his community feel more “industrial” and might
lower his property value. Jinkins further worries that construction of the tank
farm and the traffic of the large trucks would deteriorate roads, make it
difficult to get around, and be “unsightly and unpleasant.” In sum, Jinkins
has shown that he “plans to make use of the specific sites” where the effects
of Texas GulfLink’s deepwater port and its tank farm would be felt, so he
“has identified cognizable interests threatened by the project.” Id. (cleaned
up).
Moreover, Jinkins has shown that his imminent injury is traceable to
MARAD’s challenged conduct and that this injury is likely to be redressed
by a favorable decision. See Lujan, 504 U.S. at 560–61. MARAD approved
Texas GulfLink’s application to construct a deepwater port based on an
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application area that was allegedly designated in violation of the DWPA. The
agency’s approval of Texas GulfLink’s application “will lead to the
construction of a project causing the injuries” Jinkins asserts. Citizens for
Clean Air, 98 F.4th at 188. And a decision in Better Brazoria’s favor would
vacate the ROD approving Texas GulfLink’s application, preventing the
construction of the project under the current application. Thus, Better
Brazoria has demonstrated that at least one of its members would have
Article III standing to bring this challenge.
Better Brazoria has also satisfied the other two elements of
associational standing. Better Brazoria is an environmental organization, and
it is seeking to protect environmental interests, including those raised by
Jinkins. Further, neither of Better Brazoria’s claims nor the relief it requests
requires the participation of any of its members. Thus, Better Brazoria has
associational standing to bring this action, so we proceed to the merits of its
challenge.
III
“To the extent necessary to decision and when presented,” the
Administrative Procedures Act authorizes us to “decide all relevant
questions of law, interpret constitutional and statutory provisions, and
determine the meaning or applicability of the terms of an agency action.” 5
U.S.C. § 706. We are to “hold unlawful and set aside agency action, findings,
and conclusions found to be arbitrary, capricious, an abuse of discretion, or
otherwise not in accordance with law.” Id. § 706(2)(A).
Better Brazoria’s petition for review presents an issue of statutory
interpretation that we review de novo, without deference to the agency’s
interpretation of the DWPA. Loper Bright Enters. v. Raimondo, 603 U.S. 369,
412 (2024) (“Courts must exercise their independent judgment in deciding
whether an agency has acted within its statutory authority, as the APA
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requires.”). We must “apply[] all relevant interpretive tools” to determine
what reading of the statute “is best.” Id. at 400.
IV
The central dispute before us is whether the DWPA requires
MARAD to include a proposed deepwater port’s pipelines in its application
area.
Better Brazoria argues that it does: Section 1504(d)(1) requires the
Secretary to publish a description of “an application area encompassing the
deepwater port site,” and § 1502(9)(B) defines “deepwater port” to
“include[] all components and equipment, including pipelines.” 33 U.S.C.
§§ 1502(9)(B), 1504(d)(1) (emphases added). Taking these provisions
together, Better Brazoria contends, the DWPA requires MARAD to
designate an application area that encompasses the entire deepwater port
site, including the deepwater port’s pipelines.
In contrast, the Government and Texas GulfLink argue that the
DWPA gives MARAD complete discretion to designate an application area
within a statutory maximum, so the agency may choose to exclude a
deepwater port’s pipelines from its application area. They point to
§ 1504(d)(2), which defines “application area” as “any reasonable
geographical area within which a deepwater port may be constructed and
operated.” Id. § 1504(d)(2). This provision sets a limit on the maximum size
of an application area—it “shall not exceed a circular zone, the center of
which is the principal point of loading and unloading at the port, and the
radius of which is the distance from such point to the high water mark of the
nearest adjacent coastal State”—but it sets no minimum. Id. Thus, according
to the Government and Texas GulfLink, MARAD has unfettered discretion
to designate any reasonable application area within this maximum zone.
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A
To resolve this dispute, we start with the plain language of the
DWPA. Park ‘N Fly, Inc. v. Dollar Park & Fly, Inc., 469 U.S. 189, 194 (1985)
(“Statutory construction must begin with the language employed by
Congress and the assumption that the ordinary meaning of that language
accurately expresses the legislative purpose.”). Section 1504(d)(1) states that
“the Secretary shall publish a description in the Federal Register of an
application area encompassing the deepwater port site.” 33 U.S.C.
§ 1504(d)(1). This provision imposes a mandatory requirement on the
Secretary, who shall publish a description that encompasses the deepwater port
site. The ordinary meaning of “encompass” is to encircle, surround,
envelop, or enclose. See Encompass, Oxford English Dictionary
(Mar. 2026), https://doi.org/10.1093/OED/2042550495 (“To encircle as a
ring or girdle; to surround, bound on all sides.”); Encompass, Merriam-
Webster (2026), https://www.merriam-
webster.com/dictionary/encompass [https://perma.cc/5MXH-K2UV]
(defining “encompass” as to “envelop,” “form a circle about,” or
“enclose”). Thus, under § 1504(d)(1), an application area must surround the
“deepwater port site.”
“Deepwater port” is a technical term that lacks an ordinary meaning,
but the DWPA provides a statutory definition for the term. “When
Congress takes the trouble to define the terms it uses, a court must respect
its definitions as ‘virtually conclusive.’” Dep’t of Agric. Rural Dev. Rural
Hous. Serv. v. Kirtz, 601 U.S. 42, 59 (2024) (quoting Sturgeon v. Frost, 587
U.S. 28, 56 (2019)). We may “deviate from a statutory definition only when
applying the definition would be incompatible with Congress’s regulatory
scheme or would destroy one of the statute’s major purposes.” Id. at 60
(cleaned up).
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The DWPA’s definition of “deepwater port” expressly “includes all
components and equipment, including pipelines . . . to the extent they are
located seaward of the high water mark.” 33 U.S.C. § 1502(9)(B).
Construing § 1504(d)(1) in light of this definition, the DWPA requires the
Secretary to designate an application area that surrounds the entire
deepwater port site, which includes the port’s pipelines “to the extent they
are located seaward of the high water mark.” Id.
Reading § 1504(d)(2) with an eye to § 1502(9)’s definition of
“deepwater port” bolsters this conclusion. Section 1504(d)(2) defines
“application area” as “any reasonable geographical area within which a
deepwater port may be constructed and operated.” Id. § 1504(d)(2).
Interpreting this provision with § 1502(9)’s definition in mind, the statute
requires an application area to include the area within which the deepwater
port—including its pipelines—may be constructed and operated.
The Government offers three textual arguments to counter this
interpretation, but none is persuasive.
First, the Government argues that the DWPA’s definition of
“application area” is more specific than its definition of “deepwater port”
because the former definition appears in the section governing procedures
for issuing licenses, whereas the latter definition appears in a definitions
section that applies to the DWPA as a whole. The Government invokes the
general/specific canon to argue that the specific definition of “application
area” in § 1504(d)(2) should govern over the more general definition of
“deepwater port.”
The Government misconstrues the general/specific canon. That
canon instructs that when “a general permission or prohibition is
contradicted by a specific prohibition or permission,” courts should
“eliminate the contradiction” by construing the specific provision as an
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exception to the general one. RadLAX Gateway Hotel, LLC v. Amalgamated
Bank, 566 U.S. 639, 645 (2012). But the mere fact that a provision appears in
a definitions section does not necessarily mean that it is more “general” than
a provision appearing elsewhere in the statute. Here, § 1502(9) provides a
specific definition of “deepwater port,” and § 1504(d) defines “application
area” by referencing the defined term “deepwater port.”
The Government contends that this reading interprets “deepwater
port” and “application area” as having coterminous definitions, thus
rendering § 1504(d)(2)’s definition of “application area” superfluous. In
reality, the Government’s interpretation would introduce superfluity;
reading § 1504(d)(2) to grant MARAD complete discretion to designate an
application area within the maximum zone would render § 1504(d)(1)’s
requirement that an application area “encompass[] the deepwater port site”
a nullity. 33 U.S.C. § 1504(d)(1). This reading “would violate the cardinal
rule that, if possible, effect shall be given to every clause and part of a
statute.” D. Ginsberg & Sons, Inc. v. Popkin, 285 U.S. 204, 208 (1932).
The best reading of § 1504(d) harmonizes that provision’s subparts.
Section 1504(d)(1) sets a minimum size of an application area: it must at least
“encompass[] the deepwater port site.” 33 U.S.C. § 1504(d)(1). The next
paragraph sets the maximum size of an application area, and it gives the
Secretary discretion to designate “any reasonable geographical area” within
that zone as long as the application area encompasses the deepwater port site.
Id. § 1504(d)(2). Under this reading, MARAD still has significant discretion
to designate application areas under § 1504(d)(2), but that discretion is
cabined by the important statutory limitation imposed by § 1504(d)(1).
Because this interpretation renders these two paragraphs compatible rather
than contradictory, it is the best reading of the statute. See Jones v. Hendrix,
599 U.S. 465, 478 (2023) (“Basic principles of statutory interpretation
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require that we construe [a statute’s provisions] in harmony, not set them at
cross-purposes.”).
Second, the Government asserts that the phrase “deepwater port
site” as used in § 1504(d)(1) must have a distinct meaning from the term
“deepwater port” as defined in § 1502(9). By using the phrase “deepwater
port site” instead of “deepwater port,” the Government urges, Congress
must have intended to refer to something different than the entirety of a
deepwater port’s outlying structures and pipelines.
This argument runs afoul of the consistent-usage canon. Under that
canon, “there is a presumption that a given term is used to mean the same
thing throughout a statute.” Brown v. Gardner, 513 U.S. 115, 118 (1994).
“And likewise, where the document has used one term in one place, and a
materially different term in another, the presumption is that the different
term denotes a different idea.” Antonin Scalia & Bryan A.
Garner, Reading Law: The Interpretation of Legal Texts
170 (2012).
Here, there is no material difference between the phrases “deepwater
port” and “deepwater port site.” Instead, the most natural reading is that
“deepwater port site” refers to the location where a deepwater port—as
defined by § 1502(9)—is to be constructed. See Site, Oxford English
Dictionary (June 2026), https://doi.org/10.1093/OED/8976396144
(“An area of land occupied by a building, town, etc., or which is set apart for
some purpose.”); Site, Merriam-Webster (2026),
https://www.merriam-webster.com/dictionary/site
[https://perma.cc/PH9R-D85J] (defining “site” as “the spatial location of
an actual or planned structure or set of structures (such as a building, town,
or monuments)” or “a space of ground occupied or to be occupied by a
building”). There is no textual indication that “deepwater port” should take
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on an entirely new meaning from the definition provided in § 1502(9) merely
because the phrase is followed by the word “site.” See Scalia & Garner,
supra, at 228 (“It is very rare that a defined meaning can be replaced with
another permissible meaning of the word on the basis of other textual
indications; the definition is virtually conclusive.”).
Third, the Government insists that “application area” and
“deepwater port” must have different meanings because “deepwater port”
is defined using “structural” terms (e.g., “any fixed or floating manmade
structure” or “group of such structures”), whereas “application area” is
defined in “spatial and geographic” terms (e.g., “any reasonable
geographical area”). See 33 U.S.C. §§ 1502(9)(A), 1504(d)(2). But this
argument presupposes the Government’s first argument that reading
§ 1504(d) in light of § 1502(9) would render the definitions of “application
area” and “deepwater port” coterminous. On the contrary, as discussed
above, the most natural reading of the statute is that § 1504(d)’s definition of
“application area”—“any reasonable geographical area within which a
deepwater port may be constructed and operated”—incorporates
§ 1502(9)’s definition of “deepwater port” by using that defined phrase. Id.
§ 1504(d)(2). Thus, the application area must encompass the deepwater port
site, including the port’s pipelines, and be at least large enough for the
construction and operation of a deepwater port, including its pipelines.
Despite the Government’s insistence, this construction introduces neither
contradiction nor superfluity to the statute.
In short, reading § 1504(d) as requiring an application area to include
a deepwater port’s proposed pipelines is the best reading of the statute
because it faithfully applies § 1502(9)’s definition of “deepwater port” and
harmonizes the first two subparts of § 1504(d). As the best reading, this
interpretation is the only permissible reading of the statute. Loper Bright, 603
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U.S. at 400 (“In the business of statutory interpretation, if it is not the best,
it is not permissible.”).
B
Because the DWPA expressly defines a “deepwater port” as
“including pipelines,” 33 U.S.C. § 1502(9)(B), we may deviate from that
definition only if applying it “would be incompatible with Congress’s
regulatory scheme or would destroy one of the statute’s major purposes.”
Kirtz, 601 U.S. at 60 (cleaned up).
According to the Government and Texas GulfLink, reading the
DWPA to require that application areas include deepwater ports’ proposed
pipelines would, in fact, destroy a major purpose of the statute. They note
that underwater pipeline crossings are so common and inconsequential that
the “area off the coast of Texas and Louisiana is home to a complex web of
underwater pipelines and cables that cross each other in numerous places.”
Reading the DWPA to bar the construction of deepwater ports with
pipelines that cross any other pipelines would run counter to the DWPA’s
express purpose “to promote the construction and operation of deepwater
ports,” they argue. 33 U.S.C. § 1501(a)(5).
In response, Better Brazoria points to another purpose of the DWPA:
to “regulate the location, ownership, construction, and operation of
deepwater ports.” Id. § 1501(a)(1). Better Brazoria contends that
interpreting the DWPA to give MARAD virtually unfettered discretion to
designate “vanishingly small” application areas would undermine this
purpose and allow the agency to avoid ever having to decide between two
competing projects.
Interpreting the DWPA as requiring application areas to include
pipelines would not destroy a major purpose of the statute. The Government
and Texas GulfLink are correct that pipelines abound in the Gulf, and many
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No. 25-60202
of these pipelines intersect. 1 But the DWPA does not prohibit pipeline
crossings generally. It only requires that there be one deepwater port—
including that port’s pipelines—per application area. The vast majority of
pipelines in the Gulf run to and from platforms used for the processing and
distribution of oil or natural gas produced in the Gulf. See Deborah
Cranswick, Brief Overview of Gulf of Mexico OCS Oil and Gas Pipelines:
Installation, Potential Impacts, and Mitigation Measures, U.S. Dep’t of
the Interior Mins. Mgmt. Serv., at 5 (Aug. 2001),
https://www.boem.gov/newsroom/2001-067 [https://perma.cc/4QS3-
T5AW]. The DWPA does not prohibit a deepwater port’s proposed
pipelines from crossing any of these pipelines, as they are not “components”
or “equipment” of a deepwater port. See 33 U.S.C. § 1502(9)(B).
The DWPA is only implicated when a deepwater port’s proposed
pipelines would cross the pipelines of another deepwater port. As Texas
GulfLink acknowledges, there is currently only one deepwater port in the
Gulf—LOOP, located off the coast of Louisiana—which, like Texas
GulfLink’s proposed port, has a single underwater pipeline running from the
structure to the shore. Given the sparsity of deepwater-port pipelines in the
Gulf, it would not undermine the DWPA’s purpose of promoting the
construction of deepwater ports to require these ports’ pipelines not to cross.
To be sure, requiring MARAD to include pipelines in deepwater
ports’ application areas limits the agency’s discretion to designate
application areas and makes it more likely that application areas might
intersect. But that is a limit imposed by Congress, not this court. By imposing
_____________________
1
See Oil and