Syllabus extended to reach administrative actions when §2415(i) was added in 1982. The clear meaning of $2415(a)'s text, which has not been amended, refutes the first of these propositions, and accepting the latter would require the unrealistic conclusion that in 1982 Congress proceeded to enlarge §2415 to cover administrative proceedings by the oblique and cryptic route of inserting text expressly excluding a single administrative vehicle from the statute's reach. Pp. 96-99. (f) Although interpreting § 2415(a) as applying only to judicial actions may result in certain peculiarities, petitioners' alternative interpretation would itself result in disharmony. For instance, MMS oil and gas lease payment orders are now prospectively subject to a 7-year statute of limitations except with respect to obligations arising out of leases of Indian land. 30 U. S. C. §1724(b)(1). Given the exhortation that the Interior Secretary "aggressively carry out his trust responsibility in the administration of Indian oil and gas," § 1701(a)(4), it seems unlikely that Congress intended to impose a shorter, 6-year statute of limitations for payment orders regarding Indian lands. Finally, while cogent, petitioners' policy arguments as to why limiting §2415(a) to judicial actions frustrates the statute's purposes must be viewed in perspective. For example, because there are always policy arguments against affording the sovereign special treatment, the relevant inquiry in a case like this is simply how far Congress meant to go when it enacted the statute of limitations in question. Prior to §2415(a)'s enactment, Government contract actions were not subject to any statute of limitations. See Guaranty Trust Co. v. United States, 304 U. S. 126, 132. Absent congressional action changing this rule, it remains the law, and §2415(a) betrays no intent to change the rule as it applies to administrative proceedings. Pp. 99-101. 410 F. 3d 722, affirmed. ALITO, J., delivered the opinion of the Court, in which all other Members joined, except ROBERTS, C. J., and BREYER, J., who took no part in the consideration or decision of the case. Jeffrey A. Lamken argued the cause for petitioners. With him on the briefs was Steven R. Hunsicker. Daryl Joseffer argued the cause for respondents. With him on the brief were Solicitor General Clement, Assistant Attorney General Wooldridge, Deputy Solicitor General Opinion of the Court Kneedler, William B. Lazarus, Martin J. Lalonde, and John A. Bryson.* JUSTICE ALITO delivered the opinion of the Court. This case presents the question whether administrative payment orders issued by the Department of the Interior's Minerals Management Service (MMS) for the purpose of assessing royalty underpayments on oil and gas leases fall within 28 U. S. C. §2415(a), which sets out a 6-year statute of limitations for Government contract actions. We hold that this provision does not apply to these administrative payment orders, and we therefore affirm. I The Mineral Leasing Act of 1920 (MLA) authorizes the Secretary of the Interior to lease public-domain lands to private parties for the production of oil and gas. 41 Stat. 437, as amended, 30 U. S. C. § 181 et seq. MLA lessees are obligated to pay a royalty of at least "12.5 percent in amount or value of the production removed or sold from the lease.” § 226(b)(1)(A). In 1982, Congress enacted the Federal Oil and Gas Royalty Management Act (FOGRMA), 96 Stat. 2447, as amended, 30 U. S. C. § 1701 et seq., to address the concern that the "system of accounting with respect to royalties and other payments due and owing on oil and gas produced from such *Briefs of amici curiae urging reversal were filed for the American Petroleum Institute by Jonathan A. Hunter, Shannon S. Holtzman, and Harry M. Ng; and for the Mountain States Legal Foundation by William Perry Pendley. Jill Elise Grant, Harry R. Sachse, Thomas H. Shipps, Patricia A. Madrid, Attorney General of New Mexico, Christopher D. Coppin, Martin Lobel, and Richard Chivaro filed a brief for the Jicarilla Apache Nation et al. as amici curiae urging affirmance. Opinion of the Court lease sites [was] archaic and inadequate." §1701(a)(2). FOGRMA ordered the Secretary of the Interior to "audit and reconcile, to the extent practicable, all current and past lease accounts for leases of oil or gas and take appropriate actions to make additional collections or refunds as warranted." § 1711(c)(1). The Secretary, in turn, has assigned these duties to MMS. 30 CFR §201.100 (2006). Under FOGRMA, lessees are responsible in the first instance for the accurate calculation and payment of royalties. 30 U.S. C. § 1712(a). MMS, in turn, is authorized to audit those payments to determine whether a royalty has been overpaid or underpaid. §§ 1711(a) and (c); 30 CFR §§ 206.150(c), 206.170(d). In the event that an audit suggests an underpayment, it is MMS'1 practice to send the lessee a letter inquiring about the perceived deficiency. If, after reviewing the lessee's response, MMS concludes that the lessee owes additional royalties, MMS issues an order requiring payment of the amount due. Failure to comply with such an order carries a stiff penalty: "Any person who—(1) knowingly or willfully fails to make any royalty payment by the date as specified by [an] order... shall be liable for a penalty of up to $10,000 per violation for each day such violation continues." 30 U. S. C. § 1719(c). The Attorney General may enforce these orders in federal court. §1722(a). An MMS payment order may be appealed, first to the Director of MMS and then to the Interior Board of Land Appeals or to an Assistant Secretary. 30 CFR §§ 290.105, 290.108. While filing an appeal does not generally stay the payment order, § 218.50(c), MMS will usually suspend the order's effect after the lessee complies with applicable bonding or financial solvency requirements, § 243.8. Congress supplemented this scheme by enacting the Federal Oil and Gas Royalty Simplification and Fairness Act of 1996 (FOGRSFA), 110 Stat. 1700, as amended, 30 U. S. C. 1 MMS is not always the auditing body, as MMS may delegate its authority to the host State or an Indian tribe. 30 U. S. C. §§ 1732, 1735. Opinion of the Court § 1701 et seq. FOGRSFA adopted a prospective 7-year statute of limitations for any "judicial proceeding or demand" for royalties arising under a federal oil or gas lease. § 1724(b)(1). The parties agree that this provision applies both to judicial actions ("judicial proceeding[s]") and to MMS' administrative payment orders ("demand[s]") arising on or after September 1, 1996. Ibid. This provision does not, however, apply to judicial proceedings or demands arising from leases of Indian land or underpayments of royalties on pre-September 1, 1996, production. FOGRSFA §§ 9, 11, 110 Stat. 1717, notes following 30 U. S. C. § 1701. There is no dispute that a lawsuit in court to recover royalties owed to the Government on pre-September 1, 1996, production is covered by 28 U. S. C. §2415(a), which sets out a general 6-year statute of limitations for Government contract actions. That section, which was enacted in 1966, provides in relevant part: "Subject to the provisions of section 2416 of this title, and except as otherwise provided by Congress, every action for money damages brought by the United States or an officer or agency thereof which is founded upon any contract express or implied in law or fact, shall be barred unless the complaint is filed within six years after the right of action accrues or within one year after final decisions have been rendered in applicable administrative proceedings required by contract or by law, whichever is later." (Emphasis added.) Whether this general 6-year statute of limitations also governs MMS administrative payment orders concerning preSeptember 1, 1996, production is the question that we must decide in this case. B Petitioner BP America Production Co. holds gas leases from the Federal Government for lands in New Mexico's San Juan Basin. BP's predecessor, Amoco Production Co., first Opinion of the Court entered into these leases nearly 50 years ago, and these leases require the payment of the minimum 12.5 percent royalty prescribed by 30 U. S. C. §226(b)(1)(A). For years, Amoco calculated the royalty as a percentage of the value of the gas as of the moment it was produced at the well. In 1996, MMS sent lessees a letter directing that royalties should be calculated based not on the value of the gas at the well, but on the value of the gas after it was treated to meet the quality requirements for introduction into the Nation's mainline pipelines.2 Consistent with this guidance, MMS in 1997 ordered Amoco to pay additional royalties for the period from January 1989 through December 1996 in order to cover the difference between the value of the treated gas and its lesser value at the well. Amoco appealed the order, disputing MMS' interpretation of its royalty obligations and arguing that the payment order was in any event barred in part by the 6-year statute of limitations in 28 U. S. C. § 2415(a). The Assistant Secretary of the Interior denied the appeal and ruled that the statute of limitations was inapplicable. Amoco, together with petitioner Atlantic Richfield Co., sought review in the United States District Court for the District of Columbia, which agreed with the Assistant Secretary that §2415(a) did not govern the administrative order. Amoco Production Co. v. Baca, 300 F. Supp. 2d 1, 21 (2003). The Court of Appeals for the District of Columbia Circuit affirmed, Amoco Production Co. v. Watson, 410 F. 3d 722, 733 (2005), and we granted certiorari, 547 U. S. 1068 (2006), in order to resolve the conflict between that decision and the contrary holding of the United States Court of Appeals for the Tenth Circuit in OXY USA, Inc. v. Babbitt, 268 F. 3d 1001, 1005 (2001) (en banc). We now affirm. 2 MMS intended this letter to implement its regulations, which required lessees "to place gas in marketable condition at no cost to the Federal Government unless otherwise provided in the lease agreement." 30 CFR § 206.152(i) (1996). |