Based on the State's audit and Amoco's response, MMS issued an order to pay on May 27, 1997. Pet. App. 144a-156a. MMS determined that Amoco had erred by excluding the costs of removing excess CO2 from its gross proceeds, id. at 145a-148a, and ordered Amoco to pay additional royalties of $4,117,607 for the leases and years audited by the State, id. at 144a-145a, 153a. Be cause the audit uncovered a "consistent and systematic error" in Amoco's accounting, MMS also ordered Amoco to perform a restructured accounting for all of its leases in the San Juan Basin producing coalbed methane for the period January 1989 through August 1996. Id. at 153a. The order informed Amoco that failure to comply with its terms could give rise to civil penalties, id. at 154a, but that if Amoco timely pursued an administra tive appeal, "compliance with [the] order will be sus pended upon the posting of an adequate surety pending the outcome of the appeal," id. at 155a.