In Amoco Prod. Co. v. Village of Gambell, Alaska, 480 U.S. 531 (1987), the district court denied the complainant Village a preliminary injunction to stop Amocos exploratory activities, finding that the Village had not satisfied the traditional test for preliminary injunctions. Amoco Prod., 480 U.S. at 540. The Ninth Circuit reversed, finding that, inter alia, the district court had balanced irreparable harm improperly. Id. at 541. In granting an injunction, the Ninth Circuit stated that irreparable damage is presumed when an agency fails to evaluate thoroughly the environmental impact of a proposed action. Id. (quoting Village of Gambell v. Hodel, 774 F.2d 1414 , 1423 (9th Cir. 1985)). The Court found that the presumption applied by the Ninth Circuit is contrary to traditional equitable principles, id. at 545, and based on this error and the erroneous evaluation of another injunctive relief prong, the Court found that the Ninth Circuit had erred in directing the issuance of a preliminary injunction, id. at 546. In Amoco Production Co., 480 U.S. at 544, 107 S.Ct. 1396 (1987), the Supreme Court gave some guidance to evaluating harm connected with violations of substantive environmental statutes. It stated that substantive "environmental injury, by its nature, can seldom be adequately remedied by money damages and is often permanent or at least of long duration, i.e., irreparable." Amoco, 480 U.S. at 545, 107 S.Ct. 1396. In Amoco Production Company v. Village of Gambell, 480 U.S. 531, 107 S.Ct. 1396, 94 L.Ed.2d 542 (1987), the Supreme Court held that the protection of subsistence hunting and fishing provided by Alaska National Interest Lands Conservation Act ("ANILCA") does not extend to the outer continental shelf ("OCS"). Rather, the Court limited application of ANILCA to the geographical boundaries of the State of Alaska, which extend seaward no further than three miles. The Court's holding turned on its construction of the statutory language that defines the territorial scope of ANILCA: "land situated in Alaska." 16 U.S.C. Sec. 3102(3). It determined that the quoted language has a "precise geographic/political meaning" that by definition does not include the OCS. Amoco, 107 S.Ct. at 1405. It went on to determine that nothing in the structure of ANILCA, or its relationship to other statutes--namely the Alaska Statehood Act ("ASA"), Pub.L. No. 85-508, 72 Stat. 339 (1958) (codified as amended at note preceding 48 U.S.C. Sec. 21) and ANCSA--compelled a contrary conclusion. Amoco, 107 S.Ct. at 1406-08. The Court then stated: "When statutory language is plain, and nothing in the Act's structure or relationship to other statutes calls into question this plain meaning, that is ordinarily 'the end of the matter.' " Id. at 1408 (quoting Chevron U.S.A., Inc. v. Natural Resources Defense Council, Inc., 467 U.S. 837, 842, 104 S.Ct. 2778, 2786, 81 L.Ed.2d 694 (1984)). In Amoco Production Co. v. Vill. of Gambell, 480 U.S. 531, 548 n. 14, 107 S.Ct. 1396, 94 L.Ed.2d 542 (1987), the Court distinguished a statute referring to land "in Alaska" from a statute referring to "public lands which are actually occupied." 480 U.S. at 547-48 n. 14, 107 S.Ct. 1396. The Court explained that while "in Alaska" had a "precise geographical/political meaning," the phrase "public lands which are actually occupied" did not and was properly construed to include substantial areas of adjacent waters. Id. (citing Hynes v. Grimes Packing Co., 337 U.S. 86, 110-16, 69 S.Ct. 968, 93 L.Ed. 1231 (1949)). In Amoco Production Co. v. Village of Gambell, 480 U.S. 531, 107 S.Ct. 1396, 94 L.Ed.2d 542 (1987), the Court rejected the assertion that the Outer Continental Shelf (OCS) is not "Federal land" because the United States does not hold title to it. Id. at 548 n. 15, 107 S.Ct. at 1406 n. 15. The Court explained in dictum that, while the United States may not hold "title" to the OCS, it was hesitant to conclude that the United States did not have "title" to "any interests therein." Id. But its dictum indicates only that, while the United States may not hold title to land, it may hold title to interests (e.g., mineral rights) in that land.