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Abstract: Environmental problems are typically addressed by fragmented governance institutions. Fragmentation can present serious barriers to resolving environmental conflicts, but can also offer benefits. The CALFED experience should not be seen as demonstrating that unified governance is necessarily superior. Rather, it is a reminder that a fragmented governance strategy is not likely to succeed without strong leadership and tools for resolving inter-agency conflicts. [Copyright &y& Elsevier]

Examines California's utilization of the Coastal Zone Management Act (CZMA) to influence outer continental shelf (OCS) energy development; Overview of the history of he conflicts between California and the federal government regarding OCS energy development; Analysis of the Ninth Circuit's decision in the latest battle, "California Coastal Commission v. Norton"; Conclusion that the Ninth Circuit was correct in holding that the suspension of thirty-six OCS leases off California are subject to state consistency review pursuant to section 307(c)(1) of the CZMA.